]]>http://www.compliancebeat.com/planning-compliance-failures/feed/0We all want a compliance program that prevents and detects compliance failures before they happen. That is usually not what happens. Even the best programs and the best corporate cultures occasionally will face issues of misconduct.We all want a compliance program that prevents and detects compliance failures before they happen. That is usually not what happens. Even the best programs and the best corporate cultures occasionally will face issues of misconduct. It is important for organizations to spend some time thinking about and preparing for that eventuality. In this episode,…Eric Morehead21:42Tips on Gifts: What are Three Things to Consider Regarding Gift and Entertainment Compliance Programshttp://www.compliancebeat.com/tips-gifts-three-things-consider-regarding-gift-entertainment-compliance-program/
http://www.compliancebeat.com/tips-gifts-three-things-consider-regarding-gift-entertainment-compliance-program/#respondWed, 05 Dec 2018 22:05:52 +0000http://www.compliancebeat.com/?p=2479This week Eric spends a few minutes discussing some key elements to think about when trying to get the message out about gifts and entertainment and managing those frequent holiday calls (and issues) that revolve around the giving season.

]]>http://www.compliancebeat.com/tips-gifts-three-things-consider-regarding-gift-entertainment-compliance-program/feed/0This week Eric spends a few minutes discussing some key elements to think about when trying to get the message out about gifts and entertainment and managing those frequent holiday calls (and issues) that revolve around the giving season.This week Eric spends a few minutes discussing some key elements to think about when trying to get the message out about gifts and entertainment and managing those frequent holiday calls (and issues) that revolve around the giving season.Eric Morehead17:33What is Monitoring and Auditing in an Effective Compliance and Ethics Program?http://www.compliancebeat.com/monitoring-auditing-effective-compliance-ethics-program/
http://www.compliancebeat.com/monitoring-auditing-effective-compliance-ethics-program/#respondWed, 28 Nov 2018 20:58:27 +0000http://www.compliancebeat.com/?p=2476This week Eric talks about one of the hallmarks of the Sentencing Guidelines that is sometimes overlooked or not as carefully understood. Monitoring and auditing is sometimes reduced to reporting, but it is so much more. To guide us on the journey, Eric reviews the language and notes in the Sentencing Guidelines themselves and discusses…

]]>http://www.compliancebeat.com/monitoring-auditing-effective-compliance-ethics-program/feed/0This week Eric talks about one of the hallmarks of the Sentencing Guidelines that is sometimes overlooked or not as carefully understood. Monitoring and auditing is sometimes reduced to reporting, but it is so much more. To guide us on the journey,This week Eric talks about one of the hallmarks of the Sentencing Guidelines that is sometimes overlooked or not as carefully understood. Monitoring and auditing is sometimes reduced to reporting, but it is so much more. To guide us on the journey, Eric reviews the language and notes in the Sentencing Guidelines themselves and discusses…Eric Morehead26:16Our 100th Episode! And Manager Compliance Communication Supporthttp://www.compliancebeat.com/100th-episode-manager-compliance-communication-support/
http://www.compliancebeat.com/100th-episode-manager-compliance-communication-support/#respondWed, 21 Nov 2018 16:44:43 +0000http://www.compliancebeat.com/?p=2474This week we celebrate our 100th episode of Compliance Beat! Thanks to everyone who has been a loyal listener. Instead of sending presents to us, we present a listener-requested topic, some practical discussions on how to prepare and put together manager-led communications — sometimes called manager toolkits. As always, please subscribe to the podcast if…

]]>http://www.compliancebeat.com/100th-episode-manager-compliance-communication-support/feed/0This week we celebrate our 100th episode of Compliance Beat! Thanks to everyone who has been a loyal listener. Instead of sending presents to us, we present a listener-requested topic, some practical discussions on how to prepare and put together manag...This week we celebrate our 100th episode of Compliance Beat! Thanks to everyone who has been a loyal listener. Instead of sending presents to us, we present a listener-requested topic, some practical discussions on how to prepare and put together manager-led communications — sometimes called manager toolkits. As always, please subscribe to the podcast if…Eric Morehead17:21Roy Snell Interview, Part IIhttp://www.compliancebeat.com/roy-snell-interview-part-ii/
http://www.compliancebeat.com/roy-snell-interview-part-ii/#respondWed, 14 Nov 2018 17:26:45 +0000http://www.compliancebeat.com/?p=2470Join us for Part II of a special interview with Roy Snell. Roy is our first guest to appear twice and he has graciously joined us again just as he is leaving his role as the CEO of the HCCA and the SCCE. In this episode Eric and Roy talk a little about the present…

]]>http://www.compliancebeat.com/roy-snell-interview-part-ii/feed/0Join us for Part II of a special interview with Roy Snell. Roy is our first guest to appear twice and he has graciously joined us again just as he is leaving his role as the CEO of the HCCA and the SCCE. In this episode Eric and Roy talk a little about...Join us for Part II of a special interview with Roy Snell. Roy is our first guest to appear twice and he has graciously joined us again just as he is leaving his role as the CEO of the HCCA and the SCCE. In this episode Eric and Roy talk a little about the present…Eric Morehead32:51Roy Snell Interview, Part I & Three Components to Board Traininghttp://www.compliancebeat.com/roy-snell-interview-part-three-components-board-training/
http://www.compliancebeat.com/roy-snell-interview-part-three-components-board-training/#respondWed, 07 Nov 2018 18:58:09 +0000http://www.compliancebeat.com/?p=2466This time Eric has a very special guest, and our first guest to appear twice, Roy Snell. Roy was on the 2nd Episode of Compliance Beat back in 2016 and he has graciously joined us again just as he is leaving his role as the CEO of the HCCA and the SCCE. In this episode…

]]>http://www.compliancebeat.com/roy-snell-interview-part-three-components-board-training/feed/0This time Eric has a very special guest, and our first guest to appear twice, Roy Snell. Roy was on the 2nd Episode of Compliance Beat back in 2016 and he has graciously joined us again just as he is leaving his role as the CEO of the HCCA and the SCCE...This time Eric has a very special guest, and our first guest to appear twice, Roy Snell. Roy was on the 2nd Episode of Compliance Beat back in 2016 and he has graciously joined us again just as he is leaving his role as the CEO of the HCCA and the SCCE. In this episode…Eric Morehead33:59Three Compliance Communication Ideashttp://www.compliancebeat.com/three-compliance-communication-ideas/
http://www.compliancebeat.com/three-compliance-communication-ideas/#respondWed, 31 Oct 2018 20:56:02 +0000http://www.compliancebeat.com/?p=2459We’ve been away and had some technical difficulties with our Compliance Beat website — but we’re back! You can’t keep a compliance podcast down! This week Eric talks about three creative ways to approach one of the more esoteric parts of an effective compliance program: informal communications. Eric talks about thinking outside the box, using…

]]>http://www.compliancebeat.com/three-compliance-communication-ideas/feed/0We’ve been away and had some technical difficulties with our Compliance Beat website — but we’re back! You can’t keep a compliance podcast down! This week Eric talks about three creative ways to approach one of the more esoteric parts of an effective c...We’ve been away and had some technical difficulties with our Compliance Beat website — but we’re back! You can’t keep a compliance podcast down! This week Eric talks about three creative ways to approach one of the more esoteric parts of an effective compliance program: informal communications. Eric talks about thinking outside the box, using…Eric Morehead23:16Towards a Universal Code of Conducthttp://www.compliancebeat.com/towards-universal-code-conduct/
http://www.compliancebeat.com/towards-universal-code-conduct/#respondWed, 10 Oct 2018 21:50:03 +0000http://www.compliancebeat.com/?p=2456This time Eric talks about three components that every code should have to be universally accepted by the organization’s stakeholders. First, the code should apply to everyone, from the top of the organization to those third parties that represent the organization. Second, there should be one code. Organizations that still have regional codes or different…

]]>http://www.compliancebeat.com/towards-universal-code-conduct/feed/0This time Eric talks about three components that every code should have to be universally accepted by the organization’s stakeholders. First, the code should apply to everyone, from the top of the organization to those third parties that represent the ...This time Eric talks about three components that every code should have to be universally accepted by the organization’s stakeholders. First, the code should apply to everyone, from the top of the organization to those third parties that represent the organization. Second, there should be one code. Organizations that still have regional codes or different…Eric Morehead19:11Baylor University… Again: How The Four Rules of Crisis Management Applyhttp://www.compliancebeat.com/baylor-university-four-rules-crisis-management-apply/
http://www.compliancebeat.com/baylor-university-four-rules-crisis-management-apply/#respondWed, 03 Oct 2018 18:02:10 +0000http://www.compliancebeat.com/?p=2454Eric revisits the (still) ongoing issues surrounding misconduct, governance, compliance and crisis management that swirl around Baylor. After first discussing the different paths that Baylor and Penn State, for example, took back in our Compliance Beat Podcast in December 2016, we are still discussing the path that Baylor has taken — and the paths that…

]]>http://www.compliancebeat.com/baylor-university-four-rules-crisis-management-apply/feed/0Eric revisits the (still) ongoing issues surrounding misconduct, governance, compliance and crisis management that swirl around Baylor. After first discussing the different paths that Baylor and Penn State, for example,Eric revisits the (still) ongoing issues surrounding misconduct, governance, compliance and crisis management that swirl around Baylor. After first discussing the different paths that Baylor and Penn State, for example, took back in our Compliance Beat Podcast in December 2016, we are still discussing the path that Baylor has taken — and the paths that…Eric Morehead20:20Crisis! Four Rules for Crisis Management and Compliance’s Rolehttp://www.compliancebeat.com/crisis-four-rules-crisis-management-compliances-role/
http://www.compliancebeat.com/crisis-four-rules-crisis-management-compliances-role/#respondTue, 25 Sep 2018 23:03:50 +0000http://www.compliancebeat.com/?p=2452This week Eric talks crisis management, and in particular, Steve Denning’s Four Rules of Crisis Management. We talk about how the role of compliance intersects to crisis situations. Eric also talks about two upcoming webcasts, one Bullying in the Workplace: A Comprehensive Ethics & Compliance Overview will be on Thursday, Oct 18th at 1:00 PM…

]]>http://www.compliancebeat.com/crisis-four-rules-crisis-management-compliances-role/feed/0This week Eric talks crisis management, and in particular, Steve Denning’s Four Rules of Crisis Management. We talk about how the role of compliance intersects to crisis situations. Eric also talks about two upcoming webcasts,This week Eric talks crisis management, and in particular, Steve Denning’s Four Rules of Crisis Management. We talk about how the role of compliance intersects to crisis situations. Eric also talks about two upcoming webcasts, one Bullying in the Workplace: A Comprehensive Ethics & Compliance Overview will be on Thursday, Oct 18th at 1:00 PM…Eric Morehead21:133 Strategies for a Reluctant Board of Directorshttp://www.compliancebeat.com/3-strategies-reluctant-board-directors/
http://www.compliancebeat.com/3-strategies-reluctant-board-directors/#respondThu, 13 Sep 2018 20:55:33 +0000http://www.compliancebeat.com/?p=2450This time Eric talks about three different approaches compliance officers can take when dealing with a board of directors that is reluctant to spend time and resources on compliance, or when dealing with a board that is perhaps not as familiar with compliance and ethics concerns.

]]>http://www.compliancebeat.com/3-strategies-reluctant-board-directors/feed/0This time Eric talks about three different approaches compliance officers can take when dealing with a board of directors that is reluctant to spend time and resources on compliance, or when dealing with a board that is perhaps not as familiar with com...This time Eric talks about three different approaches compliance officers can take when dealing with a board of directors that is reluctant to spend time and resources on compliance, or when dealing with a board that is perhaps not as familiar with compliance and ethics concerns.Eric Morehead15:58Three Arguments for Compliance (Budget)http://www.compliancebeat.com/three-arguments-compliance-budget/
http://www.compliancebeat.com/three-arguments-compliance-budget/#respondWed, 29 Aug 2018 20:57:18 +0000http://www.compliancebeat.com/?p=2448This time Eric walks through three different areas to consider when making the case internally for compliance resources or specific compliance initiatives. We discuss three different areas to cover, regulatory or risk issues, empirical data and benchmarking and making the functional business case. Eric provides a few examples and talks about how having a well-rounded…

]]>http://www.compliancebeat.com/three-arguments-compliance-budget/feed/0This time Eric walks through three different areas to consider when making the case internally for compliance resources or specific compliance initiatives. We discuss three different areas to cover, regulatory or risk issues,This time Eric walks through three different areas to consider when making the case internally for compliance resources or specific compliance initiatives. We discuss three different areas to cover, regulatory or risk issues, empirical data and benchmarking and making the functional business case. Eric provides a few examples and talks about how having a well-rounded…Eric Morehead13:56Three Ways To Break Compliance Program Routinehttp://www.compliancebeat.com/three-ways-break-compliance-program-routine/
http://www.compliancebeat.com/three-ways-break-compliance-program-routine/#respondWed, 22 Aug 2018 20:23:19 +0000http://www.compliancebeat.com/?p=2444To compliance officers, very often, routine is good. But routine can lead to communication and training fatigue — and an overall program that doesn’t really reach the stakeholders you are trying to speak to. In this episode Eric talks about three different ways you might try to break the normal routine and have more success…

]]>http://www.compliancebeat.com/three-ways-break-compliance-program-routine/feed/0To compliance officers, very often, routine is good. But routine can lead to communication and training fatigue — and an overall program that doesn’t really reach the stakeholders you are trying to speak to.To compliance officers, very often, routine is good. But routine can lead to communication and training fatigue — and an overall program that doesn’t really reach the stakeholders you are trying to speak to. In this episode Eric talks about three different ways you might try to break the normal routine and have more success…Eric Morehead14:24Three Tips for Communicating and Training on Complex Compliance Topicshttp://www.compliancebeat.com/three-tips-communicating-training-complex-compliance-topics/
http://www.compliancebeat.com/three-tips-communicating-training-complex-compliance-topics/#respondMon, 06 Aug 2018 19:57:17 +0000http://www.compliancebeat.com/?p=2385We’re back! After a brisk summer holiday, Compliance Beat returns with a discussion about how to approach complex compliance topic discussions. Eric spends some time talking about using “real world” examples, leading with your organization’s policy and values, and figuring out some ways to get the stakeholders more directly involved — and hopefully invested. Join…

]]>http://www.compliancebeat.com/three-tips-communicating-training-complex-compliance-topics/feed/0We’re back! After a brisk summer holiday, Compliance Beat returns with a discussion about how to approach complex compliance topic discussions. Eric spends some time talking about using “real world” examples,We’re back! After a brisk summer holiday, Compliance Beat returns with a discussion about how to approach complex compliance topic discussions. Eric spends some time talking about using “real world” examples, leading with your organization’s policy and values, and figuring out some ways to get the stakeholders more directly involved — and hopefully invested. Join…Eric Morehead15:09Three Considerations for Compliance Reportinghttp://www.compliancebeat.com/three-considerations-compliance-reporting/
http://www.compliancebeat.com/three-considerations-compliance-reporting/#respondMon, 16 Jul 2018 22:21:09 +0000http://www.compliancebeat.com/?p=2382This time Eric talks about three inquiries that compliance officers might want to make when considering their internal reporting process and resources. Often organizations spend a good deal of time on tools and other systems for reporting but really should first take a step back and investigate what is going on at the organization currently,…

]]>http://www.compliancebeat.com/three-considerations-compliance-reporting/feed/0This time Eric talks about three inquiries that compliance officers might want to make when considering their internal reporting process and resources. Often organizations spend a good deal of time on tools and other systems for reporting but really sh...This time Eric talks about three inquiries that compliance officers might want to make when considering their internal reporting process and resources. Often organizations spend a good deal of time on tools and other systems for reporting but really should first take a step back and investigate what is going on at the organization currently,…Eric Morehead26:35What Does Your Code of Conduct Look Like? Some Code Design Ideas.http://www.compliancebeat.com/code-conduct-look-like-code-design-ideas/
http://www.compliancebeat.com/code-conduct-look-like-code-design-ideas/#respondTue, 03 Jul 2018 20:46:29 +0000http://www.compliancebeat.com/?p=2377This week as we get ready for the fireworks of July 4th here in the USA, let’s talk a little about the fireworks in your code document. Many organizations are focusing more on the design and look of their code documents, but what does that mean? Eric spends a little time discussing a few ideas…

]]>http://www.compliancebeat.com/code-conduct-look-like-code-design-ideas/feed/0This week as we get ready for the fireworks of July 4th here in the USA, let’s talk a little about the fireworks in your code document. Many organizations are focusing more on the design and look of their code documents, but what does that mean?This week as we get ready for the fireworks of July 4th here in the USA, let’s talk a little about the fireworks in your code document. Many organizations are focusing more on the design and look of their code documents, but what does that mean? Eric spends a little time discussing a few ideas…Eric Morehead12:13How Can We Encourage Reporting?http://www.compliancebeat.com/can-encourage-reporting/
http://www.compliancebeat.com/can-encourage-reporting/#respondMon, 25 Jun 2018 21:28:42 +0000http://www.compliancebeat.com/?p=2375This week Eric takes up the topic of reporting and talks about 4 different areas an organization can concentrate on to encourage employees to come forward with their concerns.

]]>http://www.compliancebeat.com/can-encourage-reporting/feed/0This week Eric takes up the topic of reporting and talks about 4 different areas an organization can concentrate on to encourage employees to come forward with their concerns.This week Eric takes up the topic of reporting and talks about 4 different areas an organization can concentrate on to encourage employees to come forward with their concerns.Eric Morehead18:36Some Thoughts on Integrating Mission and Values into Your Programhttp://www.compliancebeat.com/thoughts-integrating-mission-values-program/
http://www.compliancebeat.com/thoughts-integrating-mission-values-program/#respondWed, 06 Jun 2018 20:19:05 +0000http://www.compliancebeat.com/?p=2361Summer is here and Eric takes a few minutes to discuss some ideas on utilizing mission and values in your program’s communications and written standards. We talk often about bad culture, so let’s talk a little about leveraging good culture and strong values.

]]>http://www.compliancebeat.com/thoughts-integrating-mission-values-program/feed/0Summer is here and Eric takes a few minutes to discuss some ideas on utilizing mission and values in your program’s communications and written standards. We talk often about bad culture, so let’s talk a little about leveraging good culture and strong v...Summer is here and Eric takes a few minutes to discuss some ideas on utilizing mission and values in your program’s communications and written standards. We talk often about bad culture, so let’s talk a little about leveraging good culture and strong values.Eric Morehead10:35Tom Fox Discusses His Complete Compliance Handbookhttp://www.compliancebeat.com/tom-fox-discusses-complete-compliance-handbook/
http://www.compliancebeat.com/tom-fox-discusses-complete-compliance-handbook/#respondMon, 21 May 2018 20:09:30 +0000http://www.compliancebeat.com/?p=2357This week we have a special guest, Tom Fox, who discusses his new book “The Complete Compliance Handbook” with Eric. You can find out more about the new book, and how to order it, here. Also, don’t forget to join us and our friends at SAI Global for a FREE webinar (with 1.2 CCB CEU’s…

]]>http://www.compliancebeat.com/tom-fox-discusses-complete-compliance-handbook/feed/0This week we have a special guest, Tom Fox, who discusses his new book “The Complete Compliance Handbook” with Eric. You can find out more about the new book, and how to order it, here. Also, don’t forget to join us and our friends at SAI Global for a ...This week we have a special guest, Tom Fox, who discusses his new book “The Complete Compliance Handbook” with Eric. You can find out more about the new book, and how to order it, here. Also, don’t forget to join us and our friends at SAI Global for a FREE webinar (with 1.2 CCB CEU’s…Eric Morehead17:33Three Ways to Promote Your New Code of Conducthttp://www.compliancebeat.com/three-ways-promote-new-code-conduct/
http://www.compliancebeat.com/three-ways-promote-new-code-conduct/#respondMon, 14 May 2018 20:17:14 +0000http://www.compliancebeat.com/?p=2307This time Eric takes on a common question about some effective ways organizations can communicate, or roll-out, their new code of conduct. We get specific this time and talk about just three of the many ways you might try to get the word out. Posters, podcasts and personal reference cards, oh my! Get creative and…

]]>http://www.compliancebeat.com/three-ways-promote-new-code-conduct/feed/0This time Eric takes on a common question about some effective ways organizations can communicate, or roll-out, their new code of conduct. We get specific this time and talk about just three of the many ways you might try to get the word out. Posters,This time Eric takes on a common question about some effective ways organizations can communicate, or roll-out, their new code of conduct. We get specific this time and talk about just three of the many ways you might try to get the word out. Posters, podcasts and personal reference cards, oh my! Get creative and…Eric Morehead12:37Do Small Organizations Really Have Compliance Risk Exposure?http://www.compliancebeat.com/small-organizations-really-compliance-risks-exposure/
http://www.compliancebeat.com/small-organizations-really-compliance-risks-exposure/#respondMon, 07 May 2018 20:37:59 +0000http://www.compliancebeat.com/?p=2303This time we tackle several common misconceptions about regulatory and criminal risks for smaller and growing organizations. We’ll talk about what the Sentencing Commission statistics for organizations really show (www.ussc.gov) and how smaller and growing organizations really ought to be more mindful of the risks they face. Also, join us for TWO upcoming webinars on…

]]>http://www.compliancebeat.com/small-organizations-really-compliance-risks-exposure/feed/0Corporate Values and Your Code of Conducthttp://www.compliancebeat.com/corporate-values-code-conduct/
http://www.compliancebeat.com/corporate-values-code-conduct/#respondMon, 30 Apr 2018 19:15:34 +0000http://www.compliancebeat.com/?p=2295This time we talk about how you can evaluate how (or if) to use your organization’s values in your code. First, we talk about the current use of the values and how that might help, or hinder, their use in the code. Second, we talk about two different ways you can leverage your organization’s values…

]]>http://www.compliancebeat.com/corporate-values-code-conduct/feed/0This time we talk about how you can evaluate how (or if) to use your organization’s values in your code. First, we talk about the current use of the values and how that might help, or hinder, their use in the code. Second,This time we talk about how you can evaluate how (or if) to use your organization’s values in your code. First, we talk about the current use of the values and how that might help, or hinder, their use in the code. Second, we talk about two different ways you can leverage your organization’s values…Eric Morehead19:16Has The Compliance Officer’s Role Changed in 2018?http://www.compliancebeat.com/compliance-officers-role-changed-2018/
http://www.compliancebeat.com/compliance-officers-role-changed-2018/#respondMon, 23 Apr 2018 20:17:40 +0000http://www.compliancebeat.com/?p=2292Has the role changed? Eric thinks it’s a definite yes and discusses three ways this week. First, expectations from stakeholders from the BOD on down are different today. Demands on the compliance function, and expected results, are far greater than they were. Second, the need to divorce any lingering corporate legal duty from some of…

]]>http://www.compliancebeat.com/compliance-officers-role-changed-2018/feed/0Has the role changed? Eric thinks it’s a definite yes and discusses three ways this week. First, expectations from stakeholders from the BOD on down are different today. Demands on the compliance function, and expected results,Has the role changed? Eric thinks it’s a definite yes and discusses three ways this week. First, expectations from stakeholders from the BOD on down are different today. Demands on the compliance function, and expected results, are far greater than they were. Second, the need to divorce any lingering corporate legal duty from some of…Eric Morehead20:33Three Compliance Topics for Managers To Communicatehttp://www.compliancebeat.com/three-compliance-topics-managers-communicate/
http://www.compliancebeat.com/three-compliance-topics-managers-communicate/#respondMon, 09 Apr 2018 20:24:53 +0000http://www.compliancebeat.com/?p=2290This week we discuss three important topics for manager’s to discuss with their reports. What are some essential messages for manager’s to discuss? What topics sometimes get overlooked? Why are manager’s so important to the compliance communication process? Eric discusses all of these topics this week and focuses on the type of dialogue you should…

]]>http://www.compliancebeat.com/three-compliance-topics-managers-communicate/feed/0This week we discuss three important topics for manager’s to discuss with their reports. What are some essential messages for manager’s to discuss? What topics sometimes get overlooked? Why are manager’s so important to the compliance communication pro...This week we discuss three important topics for manager’s to discuss with their reports. What are some essential messages for manager’s to discuss? What topics sometimes get overlooked? Why are manager’s so important to the compliance communication process? Eric discusses all of these topics this week and focuses on the type of dialogue you should…Eric Morehead17:29How Do You Benchmark Your Code of Conduct?http://www.compliancebeat.com/benchmark-code-conduct/
http://www.compliancebeat.com/benchmark-code-conduct/#respondMon, 02 Apr 2018 18:42:57 +0000http://www.compliancebeat.com/?p=2287This week Eric addresses a common question: how do you benchmark a code of conduct? Eric focuses on three key areas to have a more successful benchmarking project. First, we talk about how you want to include peer codes outside your organization’s industry. Second, Eric discusses the fact that you don’t need to find “all…

]]>http://www.compliancebeat.com/benchmark-code-conduct/feed/0This week Eric addresses a common question: how do you benchmark a code of conduct? Eric focuses on three key areas to have a more successful benchmarking project. First, we talk about how you want to include peer codes outside your organization’s indu...This week Eric addresses a common question: how do you benchmark a code of conduct? Eric focuses on three key areas to have a more successful benchmarking project. First, we talk about how you want to include peer codes outside your organization’s industry. Second, Eric discusses the fact that you don’t need to find “all…Eric Morehead15:50Do Regulators Still Care About Compliance?http://www.compliancebeat.com/regulators-still-care-compliance/
http://www.compliancebeat.com/regulators-still-care-compliance/#respondMon, 26 Mar 2018 17:37:04 +0000http://www.compliancebeat.com/?p=2285Since 2016 we have heard this question frequently. The popular media, particular in the United States, has championed the idea that “regulation” is disappearing. But, in the context of compliance expectations, is that really true? Eric takes a look at three different reasons why that might not really be the case. In these days when…

]]>http://www.compliancebeat.com/regulators-still-care-compliance/feed/0Since 2016 we have heard this question frequently. The popular media, particular in the United States, has championed the idea that “regulation” is disappearing. But, in the context of compliance expectations, is that really true?Since 2016 we have heard this question frequently. The popular media, particular in the United States, has championed the idea that “regulation” is disappearing. But, in the context of compliance expectations, is that really true? Eric takes a look at three different reasons why that might not really be the case. In these days when…Eric Morehead17:36What Makes an Effective Conflicts of Interest Compliance Program?http://www.compliancebeat.com/makes-effective-conflicts-interest-compliance-program/
http://www.compliancebeat.com/makes-effective-conflicts-interest-compliance-program/#respondMon, 19 Mar 2018 21:52:15 +0000http://www.compliancebeat.com/?p=2283This time Eric talks about three aspects of an effective response to conflicts of interest. First, we discuss written standards and how a code of conduct and other materials can interplay effectively to provide helpful resources on conflicts. Second, Eric discusses disclosures, the piece of the puzzle that many organizations still do not include in…

]]>http://www.compliancebeat.com/makes-effective-conflicts-interest-compliance-program/feed/0This time Eric talks about three aspects of an effective response to conflicts of interest. First, we discuss written standards and how a code of conduct and other materials can interplay effectively to provide helpful resources on conflicts. Second,This time Eric talks about three aspects of an effective response to conflicts of interest. First, we discuss written standards and how a code of conduct and other materials can interplay effectively to provide helpful resources on conflicts. Second, Eric discusses disclosures, the piece of the puzzle that many organizations still do not include in…Eric Morehead25:15What Does Monitoring Mean in a Compliance and Ethics Program?http://www.compliancebeat.com/monitoring-mean-compliance-ethics-program/
http://www.compliancebeat.com/monitoring-mean-compliance-ethics-program/#respondTue, 06 Mar 2018 20:47:15 +0000http://www.compliancebeat.com/?p=2280This week Eric tackles what “monitoring” means in the context of a compliance and ethics program. We break it down into three main concepts. First, applying a “risk-based” process to monitoring means understanding your risks, applying those controls you have (including monitoring) and then evaluating those controls for effectiveness. Second, Eric spends a little time…

]]>http://www.compliancebeat.com/monitoring-mean-compliance-ethics-program/feed/0This week Eric tackles what “monitoring” means in the context of a compliance and ethics program. We break it down into three main concepts. First, applying a “risk-based” process to monitoring means understanding your risks,This week Eric tackles what “monitoring” means in the context of a compliance and ethics program. We break it down into three main concepts. First, applying a “risk-based” process to monitoring means understanding your risks, applying those controls you have (including monitoring) and then evaluating those controls for effectiveness. Second, Eric spends a little time…Eric Morehead17:46What is a Risk-Based Compliance Training Program?http://www.compliancebeat.com/risk-based-compliance-training-program/
http://www.compliancebeat.com/risk-based-compliance-training-program/#respondTue, 27 Feb 2018 18:41:09 +0000http://www.compliancebeat.com/?p=2276This time Eric discusses what makes a “risk-based” training program. Many organizations are in the thick of getting ready to roll out their training this spring, and it’s a good time to consider what you do to train your stakeholders on compliance risks. We talk about the February 2017 Evaluation of Corporate Compliance Programs memo…

]]>http://www.compliancebeat.com/risk-based-compliance-training-program/feed/0This time Eric discusses what makes a “risk-based” training program. Many organizations are in the thick of getting ready to roll out their training this spring, and it’s a good time to consider what you do to train your stakeholders on compliance risk...This time Eric discusses what makes a “risk-based” training program. Many organizations are in the thick of getting ready to roll out their training this spring, and it’s a good time to consider what you do to train your stakeholders on compliance risks. We talk about the February 2017 Evaluation of Corporate Compliance Programs memo…Eric Morehead20:01Three Things to Consider Regarding Compliance and Crisis Eventshttp://www.compliancebeat.com/three-things-consider-regarding-compliance-crisis-events/
http://www.compliancebeat.com/three-things-consider-regarding-compliance-crisis-events/#respondMon, 19 Feb 2018 21:55:54 +0000http://www.compliancebeat.com/?p=2273Eric, like a lot of people in the USA this Spring, is getting over a unexpected bout of the flu. It got him thinking about compliance during crisis events and how compliance interacts with business continuity planning. We spend some time talking about some ways compliance should be involved. Apologies for the poor sound quality…

]]>http://www.compliancebeat.com/three-things-consider-regarding-compliance-crisis-events/feed/0Eric, like a lot of people in the USA this Spring, is getting over a unexpected bout of the flu. It got him thinking about compliance during crisis events and how compliance interacts with business continuity planning.Eric, like a lot of people in the USA this Spring, is getting over a unexpected bout of the flu. It got him thinking about compliance during crisis events and how compliance interacts with business continuity planning. We spend some time talking about some ways compliance should be involved. Apologies for the poor sound quality…Eric Morehead18:54What Makes a Good Written Compliance Policy?http://www.compliancebeat.com/makes-good-written-compliance-policy/
http://www.compliancebeat.com/makes-good-written-compliance-policy/#respondMon, 12 Feb 2018 17:55:44 +0000http://www.compliancebeat.com/?p=2271This time we focus on the next horizon for “effective” written standards: the stand-alone compliance policy. While many organizations have tackled their code of conduct, written policies still woefully suffer from some of the same ailments we’ve cured in our codes. Eric takes time to talk about the differences between a code project and getting…

]]>http://www.compliancebeat.com/makes-good-written-compliance-policy/feed/0This time we focus on the next horizon for “effective” written standards: the stand-alone compliance policy. While many organizations have tackled their code of conduct, written policies still woefully suffer from some of the same ailments we’ve cured ...This time we focus on the next horizon for “effective” written standards: the stand-alone compliance policy. While many organizations have tackled their code of conduct, written policies still woefully suffer from some of the same ailments we’ve cured in our codes. Eric takes time to talk about the differences between a code project and getting…Eric Morehead19:35Compliance Training Trends with Brian Oderkirkhttp://www.compliancebeat.com/compliance-training-trends-brian-oderkirk/
http://www.compliancebeat.com/compliance-training-trends-brian-oderkirk/#respondMon, 05 Feb 2018 17:33:23 +0000http://www.compliancebeat.com/?p=2268This week we have a conversation with Brian Oderkirk from Edgepoint Learning about compliance training trends on the horizon. Brian has been in the eLearning and training space for about twenty years and has done just about every role in the space and working from everywhere from higher education, to corporate training and training vendors.…

]]>http://www.compliancebeat.com/compliance-training-trends-brian-oderkirk/feed/0This week we have a conversation with Brian Oderkirk from Edgepoint Learning about compliance training trends on the horizon. Brian has been in the eLearning and training space for about twenty years and has done just about every role in the space and ...This week we have a conversation with Brian Oderkirk from Edgepoint Learning about compliance training trends on the horizon. Brian has been in the eLearning and training space for about twenty years and has done just about every role in the space and working from everywhere from higher education, to corporate training and training vendors.…Eric Morehead24:38Three Things To Consider About Creative Compliance Communicationhttp://www.compliancebeat.com/three-things-consider-creative-compliance-communication/
http://www.compliancebeat.com/three-things-consider-creative-compliance-communication/#respondTue, 30 Jan 2018 18:59:04 +0000http://www.compliancebeat.com/?p=2266It’s that time of the year when compliance professionals are dusting off their annual plans for the program. That nearly always includes planning for training, but less often does it include detailed plans for communications. In this episode Eric talks about the US Sentencing Guideline standards and expectations regarding communication and then he provides three…

]]>http://www.compliancebeat.com/three-things-consider-creative-compliance-communication/feed/0It’s that time of the year when compliance professionals are dusting off their annual plans for the program. That nearly always includes planning for training, but less often does it include detailed plans for communications.It’s that time of the year when compliance professionals are dusting off their annual plans for the program. That nearly always includes planning for training, but less often does it include detailed plans for communications. In this episode Eric talks about the US Sentencing Guideline standards and expectations regarding communication and then he provides three…Eric Morehead22:01Three Code of Conduct Project Pain Pointshttp://www.compliancebeat.com/three-code-conduct-project-pain-points/
http://www.compliancebeat.com/three-code-conduct-project-pain-points/#respondMon, 22 Jan 2018 19:24:07 +0000http://www.compliancebeat.com/?p=2262Today Eric talks about three common areas he has seen clients experience issues when they undertake to update their code of conduct. First, Eric discusses getting the appropriate buy-in from all the applicable stakeholders. Involving the team and making sure everyone shares the appropriate vision is critical and failure can sometimes derail a project. Next…

]]>http://www.compliancebeat.com/three-code-conduct-project-pain-points/feed/0Today Eric talks about three common areas he has seen clients experience issues when they undertake to update their code of conduct. First, Eric discusses getting the appropriate buy-in from all the applicable stakeholders.Today Eric talks about three common areas he has seen clients experience issues when they undertake to update their code of conduct. First, Eric discusses getting the appropriate buy-in from all the applicable stakeholders. Involving the team and making sure everyone shares the appropriate vision is critical and failure can sometimes derail a project. Next…Eric Morehead19:1110 Things To Know About the EU General Data Protection Regulation (GDPR)http://www.compliancebeat.com/10-things-know-eu-general-data-protection-regulation-gdpr/
http://www.compliancebeat.com/10-things-know-eu-general-data-protection-regulation-gdpr/#respondMon, 15 Jan 2018 23:00:25 +0000http://www.compliancebeat.com/?p=2256This week Eric speaks to a Top Ten list, if you will, of topics to consider regarding the upcoming implementation of the EU’s new General Data Protection Regulation (GDPR). As with most compliance issues, small and medium sized organizations are likely to be the ones that are least prepared for this change, and a recent…

]]>http://www.compliancebeat.com/10-things-know-eu-general-data-protection-regulation-gdpr/feed/0This week Eric speaks to a Top Ten list, if you will, of topics to consider regarding the upcoming implementation of the EU’s new General Data Protection Regulation (GDPR). As with most compliance issues, small and medium sized organizations are likely...This week Eric speaks to a Top Ten list, if you will, of topics to consider regarding the upcoming implementation of the EU’s new General Data Protection Regulation (GDPR). As with most compliance issues, small and medium sized organizations are likely to be the ones that are least prepared for this change, and a recent…Eric Morehead33:02The Road Ahead: 2018 Compliance Trendshttp://www.compliancebeat.com/road-ahead-2018-compliance-trends/
http://www.compliancebeat.com/road-ahead-2018-compliance-trends/#respondMon, 08 Jan 2018 17:36:21 +0000http://www.compliancebeat.com/?p=2248After finishing another year we now embark on 2018 — and another yearly edition of trend predictions. In this episode Eric talks about a couple of key compliance risk topics that organizations will want to think about as they plan out their new year, including some significant changes that will be happening soon. We also…

]]>http://www.compliancebeat.com/road-ahead-2018-compliance-trends/feed/0After finishing another year we now embark on 2018 — and another yearly edition of trend predictions. In this episode Eric talks about a couple of key compliance risk topics that organizations will want to think about as they plan out their new year,After finishing another year we now embark on 2018 — and another yearly edition of trend predictions. In this episode Eric talks about a couple of key compliance risk topics that organizations will want to think about as they plan out their new year, including some significant changes that will be happening soon. We also…Eric Morehead31:05A Holiday Present: New DOJ Guidance on FCPAhttp://www.compliancebeat.com/holiday-present-new-doj-guidance-fcpa/
http://www.compliancebeat.com/holiday-present-new-doj-guidance-fcpa/#respondTue, 02 Jan 2018 19:48:50 +0000http://www.compliancebeat.com/?p=2245The US Attorney’s Manual was just updated prior to the holidays, an early present for organizations, and the new guidance codifies what was known as the “FCPA Pilot Program” and provides us a lot of helpful information about compliance expectations from the Department of Justice. Eric spends a few minutes going through the new chapter…

]]>http://www.compliancebeat.com/holiday-present-new-doj-guidance-fcpa/feed/0In The Middle of It All: New Research on Middle Managers and Ethical Behavior, Part 2 of 2http://www.compliancebeat.com/middle-new-research-middle-managers-ethical-behavior-part-2-2/
http://www.compliancebeat.com/middle-new-research-middle-managers-ethical-behavior-part-2-2/#respondMon, 18 Dec 2017 21:30:54 +0000http://www.compliancebeat.com/?p=2240We are very, very pleased to conclude our special discussion about some very interesting new research and data about managers and ethics this week. If you have not yet listened to PART I, we suggest you do. We will be interviewing the principal authors of a new article just published in October, titled “Middle Managers…

]]>http://www.compliancebeat.com/middle-new-research-middle-managers-ethical-behavior-part-2-2/feed/0We are very, very pleased to conclude our special discussion about some very interesting new research and data about managers and ethics this week. If you have not yet listened to PART I, we suggest you do.We are very, very pleased to conclude our special discussion about some very interesting new research and data about managers and ethics this week. If you have not yet listened to PART I, we suggest you do. We will be interviewing the principal authors of a new article just published in October, titled “Middle Managers…Eric Morehead24:34In The Middle of It All: New Research on Middle Managers and Ethical Behavior, Part I of 2http://www.compliancebeat.com/middle-new-research-middle-managers-ethical-behavior-part-2/
http://www.compliancebeat.com/middle-new-research-middle-managers-ethical-behavior-part-2/#respondMon, 11 Dec 2017 21:11:58 +0000http://www.compliancebeat.com/?p=2236We are very, very pleased to have a special discussion over the next two weeks about some very interesting new research and data about managers and ethics. We will be interviewing the principal authors of a new article just published in October, titled “Middle Managers and Corruptive Routine Translation: The Social Production of Deceptive Performance”.…

]]>http://www.compliancebeat.com/middle-new-research-middle-managers-ethical-behavior-part-2/feed/0We are very, very pleased to have a special discussion over the next two weeks about some very interesting new research and data about managers and ethics. We will be interviewing the principal authors of a new article just published in October,We are very, very pleased to have a special discussion over the next two weeks about some very interesting new research and data about managers and ethics. We will be interviewing the principal authors of a new article just published in October, titled “Middle Managers and Corruptive Routine Translation: The Social Production of Deceptive Performance”.…Eric Morehead28:55Revisiting Our 2017 Trend Predictionshttp://www.compliancebeat.com/revisiting-2017-trend-predictions/
http://www.compliancebeat.com/revisiting-2017-trend-predictions/#respondTue, 05 Dec 2017 01:33:07 +0000http://www.compliancebeat.com/?p=2164Closing the loop on some trends we thought might be important back in January of 2017. First, we all had (and still have) deregulation on our minds. So far, while there has been a lot of discussion about the possible effects of deregulation, it’s fair to say that compliance issues are still being driven by…

]]>http://www.compliancebeat.com/revisiting-2017-trend-predictions/feed/0Closing the loop on some trends we thought might be important back in January of 2017. First, we all had (and still have) deregulation on our minds. So far, while there has been a lot of discussion about the possible effects of deregulation,Closing the loop on some trends we thought might be important back in January of 2017. First, we all had (and still have) deregulation on our minds. So far, while there has been a lot of discussion about the possible effects of deregulation, it’s fair to say that compliance issues are still being driven by…Eric Morehead16:33What Do You Do To Overcome a Significant Cultural Issue?http://www.compliancebeat.com/overcome-significant-cultural-issue/
http://www.compliancebeat.com/overcome-significant-cultural-issue/#respondMon, 27 Nov 2017 14:37:06 +0000http://www.compliancebeat.com/?p=2160This time Eric addresses what to do in those extreme situations where there are significant or serious cultural issues. First, we talk about getting by-in and support of leadership for your efforts. It’s hard to imagine overcoming significant issues if there is no support from leadership in the organization. Buy-in also includes getting the operational…

]]>http://www.compliancebeat.com/overcome-significant-cultural-issue/feed/0Recent US Department of Justice Commentary and the Impact on Compliancehttp://www.compliancebeat.com/recent-us-department-justice-commentary-impact-compliance/
http://www.compliancebeat.com/recent-us-department-justice-commentary-impact-compliance/#respondTue, 14 Nov 2017 01:19:40 +0000http://www.compliancebeat.com/?p=2089What does the Deputy Attorney General’s recent comments about various Department memorandum and informal statements mean for compliance and ethics. For more information on the DAG’s October statement, you can review this excellent commentary. The statement suggests that many of the DOJ memos discussing corporate prosecutions we are familiar with may be consolidated (or revoked).…

]]>http://www.compliancebeat.com/recent-us-department-justice-commentary-impact-compliance/feed/0What does the Deputy Attorney General’s recent comments about various Department memorandum and informal statements mean for compliance and ethics. For more information on the DAG’s October statement, you can review this excellent commentary.What does the Deputy Attorney General’s recent comments about various Department memorandum and informal statements mean for compliance and ethics. For more information on the DAG’s October statement, you can review this excellent commentary. The statement suggests that many of the DOJ memos discussing corporate prosecutions we are familiar with may be consolidated (or revoked).…Eric Morehead14:12Reflecting on the SCCE’s Compliance and Ethics Institutehttp://www.compliancebeat.com/reflecting-scces-compliance-ethics-institute/
http://www.compliancebeat.com/reflecting-scces-compliance-ethics-institute/#respondMon, 06 Nov 2017 18:59:45 +0000http://www.compliancebeat.com/?p=2086This time Eric reflects on the annual SCCE Compliance and Ethics Institute in Las Vegas. While there are certainly other compliance and ethics events, the size and scope of the CEI is impressive and we noted three themes this year that apply not to just CEI, but the profession in general. First, growth — and…

]]>http://www.compliancebeat.com/reflecting-scces-compliance-ethics-institute/feed/0This time Eric reflects on the annual SCCE Compliance and Ethics Institute in Las Vegas. While there are certainly other compliance and ethics events, the size and scope of the CEI is impressive and we noted three themes this year that apply not to jus...This time Eric reflects on the annual SCCE Compliance and Ethics Institute in Las Vegas. While there are certainly other compliance and ethics events, the size and scope of the CEI is impressive and we noted three themes this year that apply not to just CEI, but the profession in general. First, growth — and…Eric Morehead20:23Three Things To Know About Third-Party Riskhttp://www.compliancebeat.com/three-things-know-third-party-risk/
http://www.compliancebeat.com/three-things-know-third-party-risk/#respondFri, 27 Oct 2017 12:38:16 +0000http://www.compliancebeat.com/?p=2079Today Eric talks about third-party risks and some ideas for every organization to think about when thinking about third-party risk.

First, we encourage everyone to think outside the box and contemplate the actual third-party risks that their specific organization faces. We often think third-party risk just applies to organizations that operate overseas or have anti-corruption risks. Third-party risks are much broader and organizations should take time to consider it.

Second, Eric talks about how third parties are the "perfect storm" for risk. It's hard to imagine any organization these days that doesn't have third-party risk. Additionally, we talk a little about how third parties are logistically hard to monitor. Eric points out that despite these difficulties, organizations are liable for the actions taken on their behalf.

Third, there is a way to reasonable manage the risk organizations of all sizes and types face from third parties. Have a plan. Be consistent. Apply your limited resources based on a risk analysis. Guiding principles for due diligence include getting as much information about the third parties as you can, understanding the business rationale and establishing the ongoing relationship parameters.

Eric also talks a little about tiering or ranking risk. We list off several factors that you can consider when ranking the risk of a third party.

]]>http://www.compliancebeat.com/three-things-know-third-party-risk/feed/0Today Eric talks about third-party risks and some ideas for every organization to think about when thinking about third-party risk. - First, we encourage everyone to think outside the box and contemplate the actual third-party risks that their specifi...Today Eric talks about third-party risks and some ideas for every organization to think about when thinking about third-party risk.<br />
<br />
First, we encourage everyone to think outside the box and contemplate the actual third-party risks that their specific organization faces. We often think third-party risk just applies to organizations that operate overseas or have anti-corruption risks. Third-party risks are much broader and organizations should take time to consider it.<br />
<br />
Second, Eric talks about how third parties are the "perfect storm" for risk. It's hard to imagine any organization these days that doesn't have third-party risk. Additionally, we talk a little about how third parties are logistically hard to monitor. Eric points out that despite these difficulties, organizations are liable for the actions taken on their behalf.<br />
<br />
Third, there is a way to reasonable manage the risk organizations of all sizes and types face from third parties. Have a plan. Be consistent. Apply your limited resources based on a risk analysis. Guiding principles for due diligence include getting as much information about the third parties as you can, understanding the business rationale and establishing the ongoing relationship parameters. <br />
<br />
Eric also talks a little about tiering or ranking risk. We list off several factors that you can consider when ranking the risk of a third party.Eric Morehead21:12Tone From the Tophttp://www.compliancebeat.com/tone-from-the-top/
http://www.compliancebeat.com/tone-from-the-top/#respondThu, 19 Oct 2017 13:23:51 +0000http://www.compliancebeat.com/?p=2069This time Eric talks about three practical areas to consider when evaluating and developing “tone from the top” at your organization. First, we examine what the expectations should be for the CEO or top executive of the organization. The CEO should be “present” in a real way and this can be measured by both the…

]]>http://www.compliancebeat.com/tone-from-the-top/feed/0This time Eric talks about three practical areas to consider when evaluating and developing “tone from the top” at your organization. First, we examine what the expectations should be for the CEO or top executive of the organization.This time Eric talks about three practical areas to consider when evaluating and developing “tone from the top” at your organization. First, we examine what the expectations should be for the CEO or top executive of the organization. The CEO should be “present” in a real way and this can be measured by both the…Eric Morehead15:03Compliance & Ethics Institute Preview with SCCE’s Adam Turteltaubhttp://www.compliancebeat.com/compliance-ethics-institute-preview-scces-adam-turteltaub/
http://www.compliancebeat.com/compliance-ethics-institute-preview-scces-adam-turteltaub/#respondTue, 10 Oct 2017 12:31:12 +0000http://www.compliancebeat.com/?p=2052This week, we prepare to go to the annual SCCE CEI in Las Vegas. Recent events make the trip more somber, but we look forward to seeing old friends and meeting new ones. Eric speaks with SCCE's Adam Turteltaub to discuss what's new this year at the Compliance and Ethics Institute and some of the thought that goes into planning and organizing the annual event.

Eric also talks a little about the concept of "right action" and moving forward with your goals despite conflict.

It was a year ago that we launched Compliance Beat as we were preparing for the Institute. A big thank you to everyone out there that listens to us weekly. We hope to continue to provide interesting and useful content on compliance and ethics for years to come.

]]>http://www.compliancebeat.com/compliance-ethics-institute-preview-scces-adam-turteltaub/feed/0This week, we prepare to go to the annual SCCE CEI in Las Vegas. Recent events make the trip more somber, but we look forward to seeing old friends and meeting new ones. Eric speaks with SCCE's Adam Turteltaub to discuss what's new this year at the Co...This week, we prepare to go to the annual SCCE CEI in Las Vegas. Recent events make the trip more somber, but we look forward to seeing old friends and meeting new ones. Eric speaks with SCCE's Adam Turteltaub to discuss what's new this year at the Compliance and Ethics Institute and some of the thought that goes into planning and organizing the annual event.<br />
<br />
Eric also talks a little about the concept of "right action" and moving forward with your goals despite conflict.<br />
<br />
It was a year ago that we launched Compliance Beat as we were preparing for the Institute. A big thank you to everyone out there that listens to us weekly. We hope to continue to provide interesting and useful content on compliance and ethics for years to come.Eric Morehead32:11What’s the ‘Bare Minimum’ Needed for Compliance? Part IIhttp://www.compliancebeat.com/whats-bare-minimum-needed-compliance-part-ii/
http://www.compliancebeat.com/whats-bare-minimum-needed-compliance-part-ii/#respondMon, 02 Oct 2017 23:55:39 +0000http://www.compliancebeat.com/?p=2048What is the “bare minimum” an organization needs to have an effective compliance program? Today we have part II of our discussion of what minimum requirements for an effective compliance and ethics program might be. Eric talks a little about the focus on organizational guidelines versus the Sentencing Guidelines as a whole. Eric also talks…

]]>http://www.compliancebeat.com/whats-bare-minimum-needed-compliance-part-ii/feed/0What is the “bare minimum” an organization needs to have an effective compliance program? Today we have part II of our discussion of what minimum requirements for an effective compliance and ethics program might be.What is the “bare minimum” an organization needs to have an effective compliance program? Today we have part II of our discussion of what minimum requirements for an effective compliance and ethics program might be. Eric talks a little about the focus on organizational guidelines versus the Sentencing Guidelines as a whole. Eric also talks…Eric Morehead27:37What’s the ‘Bare Minimum’ Needed for Compliance? Part Ihttp://www.compliancebeat.com/whats-bare-minimum-needed-compliance-part-2/
http://www.compliancebeat.com/whats-bare-minimum-needed-compliance-part-2/#respondMon, 25 Sep 2017 14:27:35 +0000http://www.compliancebeat.com/?p=2044What is the “bare minimum” an organization needs to have an effective compliance program? Is that even the right question? Eric talks about a common inquiry that people often have about the “Seven Hallmarks” of the Sentencing Guidelines, and that is: what must we do? In Part I of a two-part series, Eric talks about…

]]>http://www.compliancebeat.com/whats-bare-minimum-needed-compliance-part-2/feed/0What is the “bare minimum” an organization needs to have an effective compliance program? Is that even the right question? Eric talks about a common inquiry that people often have about the “Seven Hallmarks” of the Sentencing Guidelines,What is the “bare minimum” an organization needs to have an effective compliance program? Is that even the right question? Eric talks about a common inquiry that people often have about the “Seven Hallmarks” of the Sentencing Guidelines, and that is: what must we do? In Part I of a two-part series, Eric talks about…Eric Morehead25:13Effective Board of Directors Training, Part IIhttp://www.compliancebeat.com/effective-board-directors-training-part-ii/
http://www.compliancebeat.com/effective-board-directors-training-part-ii/#respondSun, 17 Sep 2017 15:57:30 +0000http://www.compliancebeat.com/?p=2041Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance professionals. At times, training your board of directors can be a real challenge. In this second part of…

]]>http://www.compliancebeat.com/effective-board-directors-training-part-ii/feed/0Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance prof...Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance professionals. At times, training your board of directors can be a real challenge. In this second part of…Eric Morehead22:45Effective Board of Directors Training, Part Ihttp://www.compliancebeat.com/effective-board-directors-training-part/
http://www.compliancebeat.com/effective-board-directors-training-part/#respondTue, 12 Sep 2017 01:13:09 +0000http://www.compliancebeat.com/?p=2035Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance professionals. At times, training your board of directors can be a real challenge. How can you effectively discuss compliance responsibilities and the key role of the board in compliance with board members, both new and old? What is the source law and standards for director's responsibility for compliance? What risks do they face for not being on top of these responsibilities? Compliance is the responsibility of the full board, not just the audit or compliance committee. Eric talks about the expectations outlined in the Sentencing Guidelines and recent United States Department of Justice Fraud Sections' new guidance, the Evaluation of Corporate Compliance Programs. Finally, Eric talks about how important it is to provide real information to the board about the content and operation of the organization's specific compliance and ethics program.

]]>http://www.compliancebeat.com/effective-board-directors-training-part/feed/0Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance prof...Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance professionals. At times, training your board of directors can be a real challenge. How can you effectively discuss compliance responsibilities and the key role of the board in compliance with board members, both new and old? What is the source law and standards for director's responsibility for compliance? What risks do they face for not being on top of these responsibilities? Compliance is the responsibility of the full board, not just the audit or compliance committee. Eric talks about the expectations outlined in the Sentencing Guidelines and recent United States Department of Justice Fraud Sections' new guidance, the Evaluation of Corporate Compliance Programs. Finally, Eric talks about how important it is to provide real information to the board about the content and operation of the organization's specific compliance and ethics program.Eric Morehead23:54What Are Some Corporate Enforcement Myths?http://www.compliancebeat.com/corporate-enforcement-myths/
http://www.compliancebeat.com/corporate-enforcement-myths/#respondMon, 04 Sep 2017 21:40:21 +0000http://www.compliancebeat.com/?p=2022This time Eric tackles some common (and stubborn) myths about regulatory enforcement and criminal liability. First, we tackle the “Trump Factor”, and the notion that reduced regulation and enforcement is on the way. Eric talks about what we really are seeing with enforcement and the statements coming from regulators and prosecutors, including the USDOJ. Eric…

]]>http://www.compliancebeat.com/corporate-enforcement-myths/feed/0This time Eric tackles some common (and stubborn) myths about regulatory enforcement and criminal liability. First, we tackle the “Trump Factor”, and the notion that reduced regulation and enforcement is on the way.This time Eric tackles some common (and stubborn) myths about regulatory enforcement and criminal liability. First, we tackle the “Trump Factor”, and the notion that reduced regulation and enforcement is on the way. Eric talks about what we really are seeing with enforcement and the statements coming from regulators and prosecutors, including the USDOJ. Eric…Eric Morehead20:19Should We Measure Our Case Management and Reporting System? What Are Some Ways to Measure?http://www.compliancebeat.com/measure-case-management-reporting-system-ways-measure/
http://www.compliancebeat.com/measure-case-management-reporting-system-ways-measure/#respondMon, 28 Aug 2017 00:00:56 +0000http://www.compliancebeat.com/?p=2019This time Eric discusses case management and reporting benchmarking. First, why is it a good idea to have a plan in place to gauge the effectiveness of this aspect of your compliance program? Eric explores why it’s a good idea to have a business case put together so that you can budget for tools in…

]]>http://www.compliancebeat.com/measure-case-management-reporting-system-ways-measure/feed/0This time Eric discusses case management and reporting benchmarking. First, why is it a good idea to have a plan in place to gauge the effectiveness of this aspect of your compliance program? Eric explores why it’s a good idea to have a business case p...This time Eric discusses case management and reporting benchmarking. First, why is it a good idea to have a plan in place to gauge the effectiveness of this aspect of your compliance program? Eric explores why it’s a good idea to have a business case put together so that you can budget for tools in…Eric Morehead18:35A Special Conversation with Ricardo Pellafonehttp://www.compliancebeat.com/special-conversation-ricardo-pellafone/
http://www.compliancebeat.com/special-conversation-ricardo-pellafone/#respondMon, 21 Aug 2017 00:22:05 +0000http://www.compliancebeat.com/?p=2016In this episode Eric has a conversation with Ricardo Pellafone, the founder of Broadcat. Eric and Ricardo have a wide-ranging discussion about compliance myths that seem to have a lot of staying power. Including, how having a lot of resources and being very busy does not necessarily equal an “effective” program. As Ricardo paraphrases Hui…

]]>http://www.compliancebeat.com/special-conversation-ricardo-pellafone/feed/0In this episode Eric has a conversation with Ricardo Pellafone, the founder of Broadcat. Eric and Ricardo have a wide-ranging discussion about compliance myths that seem to have a lot of staying power. Including,In this episode Eric has a conversation with Ricardo Pellafone, the founder of Broadcat. Eric and Ricardo have a wide-ranging discussion about compliance myths that seem to have a lot of staying power. Including, how having a lot of resources and being very busy does not necessarily equal an “effective” program. As Ricardo paraphrases Hui…Eric Morehead37:55Who Should Be Involved in a Code of Conduct Revision Project?http://www.compliancebeat.com/involved-code-conduct-revision-project/
http://www.compliancebeat.com/involved-code-conduct-revision-project/#respondSun, 13 Aug 2017 17:59:38 +0000http://www.compliancebeat.com/?p=2004In this episode Eric delves in a little deeper on a common question: who should be involved in a code of conduct project? Of course this depends a lot on what kind of project is being undertaken. Should you revise internally or bring in an outside team? What resources are available to your organization to…

]]>http://www.compliancebeat.com/involved-code-conduct-revision-project/feed/0In this episode Eric delves in a little deeper on a common question: who should be involved in a code of conduct project? Of course this depends a lot on what kind of project is being undertaken. Should you revise internally or bring in an outside team...In this episode Eric delves in a little deeper on a common question: who should be involved in a code of conduct project? Of course this depends a lot on what kind of project is being undertaken. Should you revise internally or bring in an outside team? What resources are available to your organization to…Eric Morehead11:09Is It Good To Be a “Famous” Compliance Officer?http://www.compliancebeat.com/good-famous-compliance-officer/
http://www.compliancebeat.com/good-famous-compliance-officer/#respondSat, 29 Jul 2017 14:00:06 +0000http://www.compliancebeat.com/?p=1953Interesting doings at the Department of Justice, and other recent issues have brought forward the notion of how valuable (or not) is it for an organization’s compliance officer to be “famous” or have a high profile in (or outside) the organization. Compliance officers want to market and communicate about their programs, of course, but what…

]]>http://www.compliancebeat.com/good-famous-compliance-officer/feed/0Do The Sentencing Guidelines Matter Anymore?http://www.compliancebeat.com/sentencing-guidelines-matter-anymore/
http://www.compliancebeat.com/sentencing-guidelines-matter-anymore/#respondSat, 22 Jul 2017 16:05:51 +0000http://www.compliancebeat.com/?p=1950Recently we’ve seen more activity from the Department of Justice (Fraud Section) and other regulators both in the United States and internationally that address compliance and ethics program standards and effectiveness. One topic that’s come up informally in some conversations is whether the Sentencing Guidelines still hold a central role in defining “effectiveness” for a…

]]>http://www.compliancebeat.com/sentencing-guidelines-matter-anymore/feed/0What Do We Make of Newer Guidance from USDOJ and Others?Recently we've seen more activity from the Department of Justice (Fraud Section) and other regulators both in the United States and internationally that address compliance and ethics program standards and effectiveness. One topic that's come up informally in some conversations is whether the Sentencing Guidelines still hold a central role in defining "effectiveness" for a compliance program. Eric addresses these recent questions head-on. The Sentencing Guidelines have staying power -- going back to 1991. And they still underpin most, if not all, of the standards and guidance we see not only from the Department of Justice in the USA, but also internationally. Eric talks also about how the US Sentencing Guidelines' success hinges on their unique nature and design. While new guidance and standards build and adapt these base standards, the origin and basics remain the same. The Guidelines aren't going away. Bottom line. Guidance from the USDOJ and other organizations have changed and been abandoned over time and as administrations change in particular. While the <a href="https://www.justice.gov/criminal-fraud/page/file/937501/download">guidance</a> from the Fraud Section is new and evolutionary, it is subject to change in a way the Sentencing Guidelines are not.Eric Morehead13:18Tips for Compliance and Ethics Program Incentiveshttp://www.compliancebeat.com/tips-compliance-ethics-program-incentives/
http://www.compliancebeat.com/tips-compliance-ethics-program-incentives/#respondSat, 15 Jul 2017 20:52:51 +0000http://www.compliancebeat.com/?p=1948Since incentives were first introduced in the Sentencing Guidelines there has been little guidance about what exactly make up incentives for compliance. It’s also probably no surprise that one of the most underdeveloped parts of many compliance and ethics programs is the application of incentives. In this episode Eric talks about some practical things organizations…

]]>http://www.compliancebeat.com/tips-compliance-ethics-program-incentives/feed/0Since incentives were first introduced in the Sentencing Guidelines there has been little guidance about what exactly make up incentives for compliance. It’s also probably no surprise that one of the most underdeveloped parts of many compliance and eth...Since incentives were first introduced in the Sentencing Guidelines there has been little guidance about what exactly make up incentives for compliance. It’s also probably no surprise that one of the most underdeveloped parts of many compliance and ethics programs is the application of incentives. In this episode Eric talks about some practical things organizations…Eric Morehead12:46Using the Web: Should You Have a Web-Based Code of Conduct?http://www.compliancebeat.com/using-web-web-based-code-conduct/
http://www.compliancebeat.com/using-web-web-based-code-conduct/#respondMon, 10 Jul 2017 20:43:57 +0000http://www.compliancebeat.com/?p=1945Should you have a web-based code of conduct? A common question that many organizations have when they are updating their code of conduct is should the code be a web-based document? If not, how might an organization use both internal and external-facing web resources? Eric has some ideas about adapting the code, and code content,…

]]>http://www.compliancebeat.com/using-web-web-based-code-conduct/feed/0Should you have a web-based code of conduct? A common question that many organizations have when they are updating their code of conduct is should the code be a web-based document? If not, how might an organization use both internal and external-facing...Should you have a web-based code of conduct? A common question that many organizations have when they are updating their code of conduct is should the code be a web-based document? If not, how might an organization use both internal and external-facing web resources? Eric has some ideas about adapting the code, and code content,…Eric Morehead12:46Keeping Compliance Front of Mindhttp://www.compliancebeat.com/keeping-compliance-front-mind/
http://www.compliancebeat.com/keeping-compliance-front-mind/#respondSat, 01 Jul 2017 13:11:02 +0000http://www.compliancebeat.com/?p=1943This time Eric talks about different ways compliance and ethics personnel can help keep the program and an ethical culture front of mind. Eric discusses how you can leverage slower times (often in the summer) to conduct site visits and otherwise engage in outreach. We also provide some practical examples of engagement activities to try…

]]>http://www.compliancebeat.com/keeping-compliance-front-mind/feed/0This time Eric talks about different ways compliance and ethics personnel can help keep the program and an ethical culture front of mind. Eric discusses how you can leverage slower times (often in the summer) to conduct site visits and otherwise engage...This time Eric talks about different ways compliance and ethics personnel can help keep the program and an ethical culture front of mind. Eric discusses how you can leverage slower times (often in the summer) to conduct site visits and otherwise engage in outreach. We also provide some practical examples of engagement activities to try…Eric Morehead10:01Three More Ways to Involve Managers in Compliance and Ethicshttp://www.compliancebeat.com/three-ways-involve-managers-compliance-ethics/
http://www.compliancebeat.com/three-ways-involve-managers-compliance-ethics/#respondSat, 24 Jun 2017 20:09:49 +0000http://www.compliancebeat.com/?p=1941In this episode Eric revisits a topic that is front-of-mind for many these days: involving managers in compliance. Eric discusses how research has shown involving the middle can improve concerns around retaliation and positively impact the culture of the organization. One way to better involve the middle is to make sure managers are armed with…

]]>http://www.compliancebeat.com/three-ways-involve-managers-compliance-ethics/feed/0In this episode Eric revisits a topic that is front-of-mind for many these days: involving managers in compliance. Eric discusses how research has shown involving the middle can improve concerns around retaliation and positively impact the culture of t...In this episode Eric revisits a topic that is front-of-mind for many these days: involving managers in compliance. Eric discusses how research has shown involving the middle can improve concerns around retaliation and positively impact the culture of the organization. One way to better involve the middle is to make sure managers are armed with…Eric Morehead17:12Compliance Communication Failureshttp://www.compliancebeat.com/compliance-communication-failures/
http://www.compliancebeat.com/compliance-communication-failures/#respondSat, 10 Jun 2017 13:32:06 +0000http://www.compliancebeat.com/?p=1938What are some common mistakes that compliance professionals make when communicating about compliance? Since 1991, when the US Sentencing Guidelines first addressed the importance of communication in tandem with formal compliance training, compliance officers have occasionally struggled with how frequently and in what ways to address compliance communication. In this episode, Eric talks about some common issues organizations have faced when considering the more informal side of efforts to educate and inform employees and other stakeholders about compliance risks and issues. Eric also focuses on ways organizations can address these common situations and how the recent the Department of Justice's recent guidance, the Evaluation of Corporate Compliance Programs, and other standards effect communication requirements and expectations. Finally, Eric also offers some specific practical ideas for organizations to consider when addressing compliance communication efforts.

]]>http://www.compliancebeat.com/compliance-communication-failures/feed/0What are some common mistakes that compliance professionals make when communicating about compliance? Since 1991, when the US Sentencing Guidelines first addressed the importance of communication in tandem with formal compliance training,What are some common mistakes that compliance professionals make when communicating about compliance? Since 1991, when the US Sentencing Guidelines first addressed the importance of communication in tandem with formal compliance training, compliance officers have occasionally struggled with how frequently and in what ways to address compliance communication. In this episode, Eric talks about some common issues organizations have faced when considering the more informal side of efforts to educate and inform employees and other stakeholders about compliance risks and issues. Eric also focuses on ways organizations can address these common situations and how the recent the Department of Justice's recent guidance, the Evaluation of Corporate Compliance Programs, and other standards effect communication requirements and expectations. Finally, Eric also offers some specific practical ideas for organizations to consider when addressing compliance communication efforts.Eric Morehead11:31Misconduct: Options (& Responsibilities) for Compliance Officers & Three Questions with Garin Bergmanhttp://www.compliancebeat.com/misconduct-options-responsibilities-compliance-officers-three-questions-garin-bergman/
http://www.compliancebeat.com/misconduct-options-responsibilities-compliance-officers-three-questions-garin-bergman/#respondSat, 03 Jun 2017 13:16:42 +0000http://www.compliancebeat.com/?p=1935What are some strategies and options for the compliance officer that is aware of misconduct occurring at their organization? This can be one of the most complicated topics that a compliance officer can face. And there are not always a lot of good solutions. But what options should the compliance officer consider? And what should the compliance office expect from their organization? This week, Eric explores the answers to these questions.

]]>http://www.compliancebeat.com/misconduct-options-responsibilities-compliance-officers-three-questions-garin-bergman/feed/0What are some strategies and options for the compliance officer that is aware of misconduct occurring at their organization? This can be one of the most complicated topics that a compliance officer can face.What are some strategies and options for the compliance officer that is aware of misconduct occurring at their organization? This can be one of the most complicated topics that a compliance officer can face. And there are not always a lot of good solutions. But what options should the compliance officer consider? And what should the compliance office expect from their organization? This week, Eric explores the answers to these questions.Eric Morehead31:03What does DOJ’s new guidance say about third-party risk? & Three Questions with Tedrick Houshhttp://www.compliancebeat.com/dojs-new-guidance-say-third-party-risk-three-questions-tedrick-housh/
http://www.compliancebeat.com/dojs-new-guidance-say-third-party-risk-three-questions-tedrick-housh/#respondThu, 18 May 2017 16:50:32 +0000http://www.compliancebeat.com/?p=1930When we think about third-party management, we often think of due diligence. The Department of Justice Fraud Section's new compliance and ethics guidance, the Evaluation of Corporate Compliance Programs, only mentions due diligence one time. The Evaluation contemplates a holistic, ongoing approach to third-party management in which the process is integrated into other functions, such as procurement.

]]>http://www.compliancebeat.com/dojs-new-guidance-say-third-party-risk-three-questions-tedrick-housh/feed/0When we think about third-party management, we often think of due diligence. The Department of Justice Fraud Section's new compliance and ethics guidance, the Evaluation of Corporate Compliance Programs, only mentions due diligence one time.When we think about third-party management, we often think of due diligence. The Department of Justice Fraud Section's new compliance and ethics guidance, the Evaluation of Corporate Compliance Programs, only mentions due diligence one time. The Evaluation contemplates a holistic, ongoing approach to third-party management in which the process is integrated into other functions, such as procurement.Eric Morehead27:14DOJ’s New Guidance & Interactive Code of Conduct & Part Two of Our Interview with Alison Taylorhttp://www.compliancebeat.com/dojs-new-guidance-interactive-code-conduct-part-two-interview-alison-taylor/
http://www.compliancebeat.com/dojs-new-guidance-interactive-code-conduct-part-two-interview-alison-taylor/#respondSun, 14 May 2017 15:47:35 +0000http://www.compliancebeat.com/?p=1926The new Department of Justice's guidance, the Evaluation of Corporate Compliance Programs, discusses the "design and accessibility" of written standards, such as your code of conduct. Does this focus on "design" in particular mean that organizations should reconsider or review the use of interactivity for their code? What does the Department's focus on "communication" and "evaluation" of written standards affect how an organizations evaluates and implements any interactive features? Eric discusses what the new focus on design and accessibility might mean and how organizations can address these expectations in their code of conduct review, revision and development processes.

]]>http://www.compliancebeat.com/dojs-new-guidance-interactive-code-conduct-part-two-interview-alison-taylor/feed/0The new Department of Justice's guidance, the Evaluation of Corporate Compliance Programs, discusses the "design and accessibility" of written standards, such as your code of conduct. Does this focus on "design" in particular mean that organizations s...The new Department of Justice's guidance, the Evaluation of Corporate Compliance Programs, discusses the "design and accessibility" of written standards, such as your code of conduct. Does this focus on "design" in particular mean that organizations should reconsider or review the use of interactivity for their code? What does the Department's focus on "communication" and "evaluation" of written standards affect how an organizations evaluates and implements any interactive features? Eric discusses what the new focus on design and accessibility might mean and how organizations can address these expectations in their code of conduct review, revision and development processes.Eric Morehead36:36The New DOJ Guidance on Code of Conduct & Part One of a Special Interview with Alison Taylorhttp://www.compliancebeat.com/new-doj-guidance-code-conduct-part-one-special-interview-alison-taylor/
http://www.compliancebeat.com/new-doj-guidance-code-conduct-part-one-special-interview-alison-taylor/#respondFri, 05 May 2017 17:55:27 +0000http://www.compliancebeat.com/?p=1918How does the new Department of Justice's new guidance, the Evaluation of Corporate Compliance Programs, from February 2017 approach the requirements for written standards, including code of conduct? Eric walks through three key takeaways from the Evaluation of Corporate Compliance Programs on how organizations should document and conduct their code of conduct development and review process. We also have Part One of a two part Special Interview with Alison Taylor of BSR.

]]>http://www.compliancebeat.com/new-doj-guidance-code-conduct-part-one-special-interview-alison-taylor/feed/0What the DOJ Guidance has to say about code of conduct development and assessment and we talk culture with Alison Taylor from BSRThis time we reflect on the new Department of Justice guidance from February 2017 and how it approaches the requirements for written standards including code of conduct. We walk through three key takeaways from the guidance on how organizations should document and conduct their code of conduct development and review process. We also have Part One of a two part Special Interview with Alison Taylor of BSR.Eric Morehead26:09Teaching Moments: What Can We Learn About Compliance Failures From Baylor University?http://www.compliancebeat.com/teaching-moments-can-learn-compliance-failures-baylor-university/
http://www.compliancebeat.com/teaching-moments-can-learn-compliance-failures-baylor-university/#respondFri, 28 Apr 2017 22:15:48 +0000http://www.compliancebeat.com/?p=1913As an alumni of Baylor University, Eric has been closely following the allegations that Baylor University violated its obligations under Title IX. Six months after his first episode looking at this issue, Baylor University, unfortunately, is still in the news. What's going on? What lessons can compliance professionals learn from Baylor University and how this compliance failure has been handled?

Regents have provided a playbook of what not to do when responding to a compliance failure. From When looking at how Baylor University has handled this situation, Eric considers three key teaching moments. First, Baylor's problems dispel any belief that private companies or private universities can handle these issues internally and without public scrutiny. Second, he considers how Baylor's response continued to damage Baylor's reputation and how reputational harm damages the University overall. Third, he talks about the importance of transparency.

At the end of the episode, Eric lays out some of the steps that Baylor University's new president, Dr. Linda Livingstone, should take to repair the reputational harm and restore confidence in the University.

]]>http://www.compliancebeat.com/teaching-moments-can-learn-compliance-failures-baylor-university/feed/0As an alumni of Baylor University, Eric has been closely following the allegations that Baylor University violated its obligations under Title IX. Six months after his first episode looking at this issue, Baylor University, unfortunately,As an alumni of Baylor University, Eric has been closely following the allegations that Baylor University violated its obligations under Title IX. Six months after his first episode looking at this issue, Baylor University, unfortunately, is still in the news. What's going on? What lessons can compliance professionals learn from Baylor University and how this compliance failure has been handled?<br />
<br />
Regents have provided a playbook of what not to do when responding to a compliance failure. From When looking at how Baylor University has handled this situation, Eric considers three key teaching moments. First, Baylor's problems dispel any belief that private companies or private universities can handle these issues internally and without public scrutiny. Second, he considers how Baylor's response continued to damage Baylor's reputation and how reputational harm damages the University overall. Third, he talks about the importance of transparency.<br />
<br />
At the end of the episode, Eric lays out some of the steps that Baylor University's new president, Dr. Linda Livingstone, should take to repair the reputational harm and restore confidence in the University.Eric Morehead16:56The Relationship Between Culture and Compliance & Special Interview with Laura Cordovahttp://www.compliancebeat.com/relationship-culture-compliance-special-interview-laura-cordova/
http://www.compliancebeat.com/relationship-culture-compliance-special-interview-laura-cordova/#respondWed, 19 Apr 2017 16:25:29 +0000http://www.compliancebeat.com/?p=1908What’s the difference between compliance and corporate culture? Is there a difference? How do they work together? In this episode, Eric looks at how two airlines, United and Delta, responded recently to challenges they faced and how their responses speak to their corporate cultures. Both airlines faced operational failures. The juxtaposition of their responses are excellent teaching moments and examples that compliance professionals can give to demonstrate the relationship between compliance and corporate culture.

]]>http://www.compliancebeat.com/relationship-culture-compliance-special-interview-laura-cordova/feed/0What’s the difference between compliance and corporate culture? Is there a difference? How do they work together? In this episode, Eric looks at how two airlines, United and Delta, responded recently to challenges they faced and how their responses spe...What’s the difference between compliance and corporate culture? Is there a difference? How do they work together? In this episode, Eric looks at how two airlines, United and Delta, responded recently to challenges they faced and how their responses speak to their corporate cultures. Both airlines faced operational failures. The juxtaposition of their responses are excellent teaching moments and examples that compliance professionals can give to demonstrate the relationship between compliance and corporate culture.Eric Morehead32:35Hot Topics in Compliance & Ethics in Europe Part IIhttp://www.compliancebeat.com/hot-topics-compliance-ethics-part-ii/
http://www.compliancebeat.com/hot-topics-compliance-ethics-part-ii/#respondWed, 12 Apr 2017 14:38:14 +0000http://www.compliancebeat.com/?p=1903As Eric returns from the Society for Corporate Compliance & Ethics European Ethics & Compliance Institute in Prague, he shares the hot topics of discussion at the conference. He discusses his three main takeaways from the conference.

]]>http://www.compliancebeat.com/hot-topics-compliance-ethics-part-ii/feed/0As Eric returns from the Society for Corporate Compliance & Ethics European Ethics & Compliance Institute in Prague, he shares the hot topics of discussion at the conference. He discusses his three main takeaways from the conference.As Eric returns from the Society for Corporate Compliance & Ethics European Ethics & Compliance Institute in Prague, he shares the hot topics of discussion at the conference. He discusses his three main takeaways from the conference.Eric Morehead11:17Hot Topics in Compliance & Ethics in Europehttp://www.compliancebeat.com/hot-topics-compliance-ethics-europe/
http://www.compliancebeat.com/hot-topics-compliance-ethics-europe/#respondMon, 03 Apr 2017 15:31:08 +0000http://www.compliancebeat.com/?p=1896Just a few years ago, Europe was considered behind the United States in compliance and ethics. That is not the case today. Eric looks at three hot topics in compliance and ethics in Europe as he prepares to leave for the Society of Corporate Compliance and Ethics European Compliance & Ethics Institute in Prague this week.

]]>http://www.compliancebeat.com/hot-topics-compliance-ethics-europe/feed/0Just a few years ago, Europe was considered behind the United States in compliance and ethics. That is not the case today. Eric looks at three hot topics in compliance and ethics in Europe as he prepares to leave for the Society of Corporate Complianc...Just a few years ago, Europe was considered behind the United States in compliance and ethics. That is not the case today. Eric looks at three hot compliance and ethics in Europe as he prepares to leave for the Society of Corporate Compliance and Ethics European Compliance & Ethics Institute in Prague this week.Eric Morehead11:58Risk Assessment and the Evaluation of Corporate Compliance Programs & Three Questions with Matt Kellyhttp://www.compliancebeat.com/risk-assessment-evaluation-corporate-compliance-programs-three-questions/
http://www.compliancebeat.com/risk-assessment-evaluation-corporate-compliance-programs-three-questions/#respondWed, 29 Mar 2017 13:00:14 +0000http://www.compliancebeat.com/?p=1887When we are talking about risk assessment and the Evaluation of Corporate Compliance Programs, there are three areas to really focus on. First, the Evaluation considers how organizations create and use their methodology for risk assessment. Second, this new guidance focuses on how the data you gather informs the choices you make in your compliance…

]]>http://www.compliancebeat.com/risk-assessment-evaluation-corporate-compliance-programs-three-questions/feed/0When we are talking about risk assessment and the Evaluation of Corporate Compliance Programs, there are three areas to really focus on. First, the Evaluation considers how organizations create and use their methodology for risk assessment. Second,When we are talking about risk assessment and the Evaluation of Corporate Compliance Programs, there are three areas to really focus on. First, the Evaluation considers how organizations create and use their methodology for risk assessment. Second, this new guidance focuses on how the data you gather informs the choices you make in your compliance and ethics program. Third, the Evaluation introduces the notion of manifested risk.Eric Morehead30:24The Board of Directors’ Relationship with Your Compliance Officer & the Evaluation of Corporate Compliance Programs & Three Questions with Jean-Marc Levyhttp://www.compliancebeat.com/board-directors-relationship-compliance-officer-evaluation-corporate-compliance-programs-three-questions-jean-marc-levy/
http://www.compliancebeat.com/board-directors-relationship-compliance-officer-evaluation-corporate-compliance-programs-three-questions-jean-marc-levy/#respondWed, 22 Mar 2017 18:47:03 +0000http://www.compliancebeat.com/?p=1880What does the Department of Justice Fraud Section’s new Evaluation of Corporate Compliance Programs say about your compliance officer’s relationship with your Board of Directors? There are three salient points that you can take away from the Evaluation of Corporate Compliance Programs with regard to the Board of Directors. Some of these points aren’t necessarily new concepts, but they certainly give us more guidance in terms of what the Department of Justice is looking for when considering this relationship. In this episode, Eric takes a deep dive into the Evaluation of Corporate Compliance and how it relates to your Board of Directors.

]]>http://www.compliancebeat.com/board-directors-relationship-compliance-officer-evaluation-corporate-compliance-programs-three-questions-jean-marc-levy/feed/0What does the Department of Justice Fraud Section’s new Evaluation of Corporate Compliance Programs say about your compliance officer’s relationship with your Board of Directors? There are three salient points that you can take away from the Evaluatio...What does the Department of Justice Fraud Section’s new Evaluation of Corporate Compliance Programs say about your compliance officer’s relationship with your Board of Directors? There are three salient points that you can take away from the Evaluation of Corporate Compliance Programs with regard to the Board of Directors. Some of these points aren’t necessarily new concepts, but they certainly give us more guidance in terms of what the Department of Justice is looking for when considering this relationship. In this episode, Eric takes a deep dive into the Evaluation of Corporate Compliance and how it relates to your Board of Directors.Eric Morehead24:32The Checklist That’s Not A Checklist Part 3: What does the new guidance from the DOJ Fraud Section mean?http://www.compliancebeat.com/checklist-thats-not-checklist-new-guidance-doj-fraud-section-mean/
Wed, 15 Mar 2017 13:00:47 +0000http://www.compliancebeat.com/?p=1872The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the "checklist" expands on it. If it's not a checklist, what does it all mean? How can it help you? Eric examines each of the Sample Topics and Questions that the DOJ puts forth in this new guidance.

]]>The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula....The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the "checklist" expands on it. If it's not a checklist, what does it all mean? How can it help you? Eric examines each of the Sample Topics and Questions that the DOJ puts forth in this new guidance.Eric Morehead17:01The Checklist That’s Not A Checklist Part 2: What does the new guidance from DOJ Fraud Section mean?http://www.compliancebeat.com/checklist-thats-not-checklist-part-2-new-guidance-doj-fraud-section-mean/
http://www.compliancebeat.com/checklist-thats-not-checklist-part-2-new-guidance-doj-fraud-section-mean/#respondThu, 09 Mar 2017 02:19:55 +0000http://www.compliancebeat.com/?p=1865The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the "checklist" expands on it. If it's not a checklist, what does it all mean? How can it help you? Eric examines each of the Sample Topics and Questions that the DOJ puts forth in this new guidance.

]]>http://www.compliancebeat.com/checklist-thats-not-checklist-part-2-new-guidance-doj-fraud-section-mean/feed/0The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula....The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the "checklist" expands on it. If it's not a checklist, what does it all mean? How can it help you? In part two of a three part series, Eric examines each of the Sample Topics and Questions that the DOJ puts forth in this new guidance.Eric Morehead17:32The Checklist That’s Not A Checklist Part 1: What does the new guidance from the DOJ Fraud Section mean?http://www.compliancebeat.com/checklist-thats-not-checklist-new-guidance-doj-fraud-division-mean/
http://www.compliancebeat.com/checklist-thats-not-checklist-new-guidance-doj-fraud-division-mean/#respondWed, 01 Mar 2017 21:37:44 +0000http://www.compliancebeat.com/?p=1843The Department of Justice Fraud Section released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the "checklist" expands on it. If it's not a checklist, what does it all mean? How can it help you?

]]>http://www.compliancebeat.com/checklist-thats-not-checklist-new-guidance-doj-fraud-division-mean/feed/0The Department of Justice Fraud Section released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but DOJ says it’s not a checklist or formula.The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the "checklist" expands on it.Eric Morehead18:04When and how will the organizational sentencing guidelines be amended? & Three Questions with Joe Murphyhttp://www.compliancebeat.com/will-organizational-sentencing-guidelines-amended-three-questions-joe-murphy/
http://www.compliancebeat.com/will-organizational-sentencing-guidelines-amended-three-questions-joe-murphy/#respondWed, 22 Feb 2017 14:00:41 +0000http://www.compliancebeat.com/?p=1830The Upshot this week is when you are thinking about when the organizational guidelines may be amended, take a close look at the Sentencing Commission’s priorities that come out in May or June of each year and keep an eye on who President Trump appoints to the Commission. As far as what might be amended, more talk and guidance around the concept of incentives is in order. There might be some consideration of making the fine provisions of Chapter 8 more applicable to offenses that are currently carved out.

]]>http://www.compliancebeat.com/will-organizational-sentencing-guidelines-amended-three-questions-joe-murphy/feed/0The Upshot this week is when you are thinking about when the organizational guidelines may be amended, take a close look at the Sentencing Commission’s priorities that come out in May or June of each year and keep an eye on who President Trump appoints...The Upshot this week is when you are thinking about when the organizational guidelines may be amended, take a close look at the Sentencing Commission’s priorities that come out in May or June of each year and keep an eye on who President Trump appoints to the Commission. As far as what might be amended, more talk and guidance around the concept of incentives is in order. There might be some consideration of making the fine provisions of Chapter 8 more applicable to offenses that are currently carved out.Eric Morehead35:20Busting Three Third-Party Myths & Three Questions with Eric Feldmanhttp://www.compliancebeat.com/busting-three-third-party-myths-three-questions-eric-feldman/
http://www.compliancebeat.com/busting-three-third-party-myths-three-questions-eric-feldman/#respondWed, 15 Feb 2017 14:00:17 +0000http://www.compliancebeat.com/?p=1749Eric often encounters three myths that organizations believe when considering the liability they may face because of third-party partners’ or agents’ conduct. In this episode, Eric explains why believing these myths creates liability risks for your company.

Myth No. 1: Many people believe that third-party compliance is only anti-corruption, anti-bribery, and/or potential Federal Corrupt Practices Act (FCPA) violations. Your risks, however, are much broader than just those three risk areas. Eric explains why you should be concerned about your third-party agents’ or partners’ compliance in many other risk areas.

Myth No. 2: Many organizations believe that if they are operating purely domestically and don’t conduct any business overseas, they don’t have third-party compliance concerns. It is important to realize that if your third-party agent is working overseas, you may have liability related to the third-party’s conduct overseas. Eric looks at some risk areas that you may not realize you face from third-party’s conduct overseas and how you can protect yourself from those risks.

Myth No. 3: You can rely on a third-party’s compliance program to protect your organization from liability resulting from the third-party’s conduct. Many people recognize that smaller organizations that don’t have as robust a compliance program can present a greater liability risk that larger organizations that have robust compliance program. No matter how extensive a third-party’s compliance program may be, you still face risk. Eric discusses the settlements of FCPA violations related to Panelpina World Transport Ltd., a large publicly trade, multinational corporation. In these cases, many organizations faced liability due to Panelpina’s conduct overseas. Eric explores what this means for your reliance on a third-party’s compliance program.

Three Questions with Eric Feldman, Affiliated Monitors, Inc.

Eric Feldman is the Senior Vice President, Managing Director, Corporate Ethics and Compliance at Affiliated Monitors. Eric retired from the CIA in 2011 with over 32 years of experience in Inspector General oversight and federal auditing in the executive and legislative branches of government. He has served in executive positions with Offices of Inspector General at the Department of Defense, Defense Intelligence Agency, and CIA, and was the longest serving Inspector General of the National Reconnaissance Office (NRO) from 2003-2009. At the NRO, he presided over a highly successful procurement fraud prevention and detection program, widely recognized by the Department of Justice as a model throughout the federal government. Eric is a sought-after speaker in the field of compliance and ethics. Eric’s background and experience give him unique insight into the importance of corporate culture and the future of compliance and ethics. In this interview, Eric's discussion goes far beyond the three questions, discussing issues that range from recent newsworthy compliance failures to the future of compliance and ethics.

]]>http://www.compliancebeat.com/busting-three-third-party-myths-three-questions-eric-feldman/feed/0Eric often encounters three myths that organizations believe when considering the liability they may face because of third-party partners’ or agents’ conduct. In this episode, Eric explains why believing these myths creates liability risks for your co...Eric often encounters three myths that organizations believe when considering the liability they may face because of third-party partners’ or agents’ conduct. In this episode, Eric explains why believing these myths creates liability risks for your company.<br />
<br />
Myth No. 1: Many people believe that third-party compliance is only anti-corruption, anti-bribery, and/or potential Federal Corrupt Practices Act (FCPA) violations. Your risks, however, are much broader than just those three risk areas. Eric explains why you should be concerned about your third-party agents’ or partners’ compliance in many other risk areas.<br />
<br />
Myth No. 2: Many organizations believe that if they are operating purely domestically and don’t conduct any business overseas, they don’t have third-party compliance concerns. It is important to realize that if your third-party agent is working overseas, you may have liability related to the third-party’s conduct overseas. Eric looks at some risk areas that you may not realize you face from third-party’s conduct overseas and how you can protect yourself from those risks.<br />
<br />
Myth No. 3: You can rely on a third-party’s compliance program to protect your organization from liability resulting from the third-party’s conduct. Many people recognize that smaller organizations that don’t have as robust a compliance program can present a greater liability risk that larger organizations that have robust compliance program. No matter how extensive a third-party’s compliance program may be, you still face risk. Eric discusses the settlements of FCPA violations related to Panelpina World Transport Ltd., a large publicly trade, multinational corporation. In these cases, many organizations faced liability due to Panelpina’s conduct overseas. Eric explores what this means for your reliance on a third-party’s compliance program.<br />
<br />
Three Questions with Eric Feldman, Affiliated Monitors, Inc.<br />
<br />
Eric Feldman is the Senior Vice President, Managing Director, Corporate Ethics and Compliance at Affiliated Monitors. Eric retired from the CIA in 2011 with over 32 years of experience in Inspector General oversight and federal auditing in the executive and legislative branches of government. He has served in executive positions with Offices of Inspector General at the Department of Defense, Defense Intelligence Agency, and CIA, and was the longest serving Inspector General of the National Reconnaissance Office (NRO) from 2003-2009. At the NRO, he presided over a highly successful procurement fraud prevention and detection program, widely recognized by the Department of Justice as a model throughout the federal government. Eric is a sought-after speaker in the field of compliance and ethics. Eric’s background and experience give him unique insight into the importance of corporate culture and the future of compliance and ethics. In this interview, Eric's discussion goes far beyond the three questions, discussing issues that range from recent newsworthy compliance failures to the future of compliance and ethics.Eric Morehead39:48Should you have a third-party vendor or partner code of conduct? & Three Questions with Kelly Clarkhttp://www.compliancebeat.com/third-party-vendor-partner-code-conduct-three-questions-kelly-clark/
http://www.compliancebeat.com/third-party-vendor-partner-code-conduct-three-questions-kelly-clark/#respondFri, 10 Feb 2017 00:13:38 +0000http://www.compliancebeat.com/?p=1732According to benchmarking data, less than half of organizations currently have third-party codes. There’s a current trend of partners asking each other to “sign off” or certify to codes of conduct. You must first assess your risk before answering whether you need a third-party code. Other controls you already have in place, such as contracting…

]]>http://www.compliancebeat.com/third-party-vendor-partner-code-conduct-three-questions-kelly-clark/feed/0According to benchmarking data, less than half of organizations currently have third-party codes. There’s a current trend of partners asking each other to “sign off” or certify to codes of conduct. You must first assess your risk before answering whe...When considering a third-party code, take a hard look at the purpose and audience you are trying to reach. Also consider accessibility and the communication tools you use for your employee code when drafting these documents.Eric Morehead28:07Compliance Officer Liability after VW & Takatahttp://www.compliancebeat.com/compliance-officer-liability-vw-takata/
http://www.compliancebeat.com/compliance-officer-liability-vw-takata/#respondWed, 01 Feb 2017 14:58:03 +0000http://www.compliancebeat.com/?p=1728What does the flurry of indictments against individuals at Volkswagen and Takata tell us about compliance officer liability after the Yates Memo? Eric revisits the impact of the Yates Memo on compliance officer liability with the news of these prosecutions. The Yates Memo, written by Deputy Attorney General Sally Yates and released on September 9,…

]]>http://www.compliancebeat.com/compliance-officer-liability-vw-takata/feed/0What does the flurry of indictments against individuals at Volkswagen and Takata tell us about compliance officer liability after the Yates Memo? Eric revisits the impact of the Yates Memo on compliance officer liability with the news of these prosecu...What does the flurry of indictments against individuals at Volkswagen and Takata tell us about compliance officer liability after the Yates Memo? Eric revisits the impact of the Yates Memo on compliance officer liability with the news of these prosecutions. The Yates Memo, written by Deputy Attorney General Sally Yates and released on September 9, 2015, addresses individual liability for corporate wrongdoing. In the memo, the DAG Yates lays out new guidance to Department of Justice attorneys who are prosecuting individuals involved in corporate wrongdoing. An earlier episode, "Does the Yates Memo increase my liability as a compliance officer?", examines data collected by the United States Sentencing Commission regrading the rates of criminal prosecutions of individuals involved in corporate wrongdoing.<br />
<br />
In this episode, Eric tells you why he holds to his original statement that the most important function of the Yates Memo is to open the door to and encourage important discussions about corporate culture and the importance of strong compliance and ethics programs. Volkswagen and Takata can serve as cautionary tales about the impact of a weak culture and compliance and ethics program.<br />
<br />
Eric also goes beyond the news stories and examines the affidavit in support of the criminal complaint against VW's compliance officer, Oliver Schmidt. He talks about the conduct that Schmidt allegedly engaged in that led to his arrest. He also discusses what compliance officers can do to avoid individual criminal liability.Eric Morehead16:57What are three ways to involve managers in your compliance & ethics program? & Three Questions with Gretchen Wintershttp://www.compliancebeat.com/three-ways-involve-managers-compliance-ethics-program-three-questions-gretchen-winters/
http://www.compliancebeat.com/three-ways-involve-managers-compliance-ethics-program-three-questions-gretchen-winters/#respondWed, 25 Jan 2017 14:00:51 +0000http://www.compliancebeat.com/?p=1718If you are looking for ways to involve your managers in your compliance and ethics program, three places to start are engaging managers in training, giving them tools to engage in regular communication about compliance and ethics issues, and helping build strong teams and good rapport with their direct reports.

]]>http://www.compliancebeat.com/three-ways-involve-managers-compliance-ethics-program-three-questions-gretchen-winters/feed/0If you are looking for ways to involve your managers in your compliance and ethics program, three places to start are engaging managers in training, giving them tools to engage in regular communication about compliance and ethics issues,If you are looking for ways to involve your managers in your compliance and ethics program, three places to start are engaging managers in training, giving them tools to engage in regular communication about compliance and ethics issues, and helping build strong teams and good rapport with their direct reports.Eric Morehead13:34What can you do to prevent retaliation & encourage employees to report misconduct? & Three Questions with Che Hembreyhttp://www.compliancebeat.com/can-prevent-retaliation-encourage-employees-report-misconduct-three-questions-che-hembrey/
http://www.compliancebeat.com/can-prevent-retaliation-encourage-employees-report-misconduct-three-questions-che-hembrey/#respondWed, 18 Jan 2017 14:00:16 +0000http://www.compliancebeat.com/?p=1705In order to answer this question, it’s important to first look at the data on retaliation. In three different reports, two in 2012 and one in 2015, the Ethics and Compliance Initiative examined the percentage of employees that report witnessing misconduct. These reports found that 40% to 50%, or approximately four out of ten employees,…

]]>http://www.compliancebeat.com/can-prevent-retaliation-encourage-employees-report-misconduct-three-questions-che-hembrey/feed/0In order to answer this question, it’s important to first look at the data on retaliation. In three different reports, two in 2012 and one in 2015, the Ethics and Compliance Initiative examined the percentage of employees that report witnessing miscond...When addressing concerns about reporting misconduct and retaliation in your organization, you should focus on an effective compliance and ethics program that includes structural pieces, such as clear communication that addresses employees’ fears of retaliation and strong corporate culture.Eric Morehead23:332017 Trends in Compliance & Ethics Special Editionhttp://www.compliancebeat.com/2017-trends-compliance-ethics-special-edition/
http://www.compliancebeat.com/2017-trends-compliance-ethics-special-edition/#respondWed, 11 Jan 2017 14:00:54 +0000http://www.compliancebeat.com/?p=1696What are going to be the overarching trends in compliance and ethics in 2017? In this episode, Eric talks about compliance and ethics program trends that will affect every company, no matter your size and no matter whether you are in a highly regulated space.

]]>http://www.compliancebeat.com/2017-trends-compliance-ethics-special-edition/feed/0What are going to be the overarching trends in compliance and ethics in 2017? In this episode, Eric talks about compliance and ethics program trends that will affect every company, no matter your size and no matter whether you are in a highly regulate...What are going to be the overarching trends in compliance and ethics in 2017? In this episode, Eric talks about compliance and ethics program trends that will affect every company, no matter your size and no matter whether you are in a highly regulated space.Eric Morehead16:01Should you use interactive design for your code of conduct? & Three Questions with Ricardo Pellafonehttp://www.compliancebeat.com/use-interactive-design-code-conduct-three-questions-ricardo-pellafone/
http://www.compliancebeat.com/use-interactive-design-code-conduct-three-questions-ricardo-pellafone/#respondWed, 04 Jan 2017 14:00:45 +0000http://www.compliancebeat.com/?p=1636When determining whether to use an interactive design, be sure to spend some time thinking about these three questions: How do your stakeholders interact with your current code of conduct? What is your organization's communication style? How do you maintain your code of conduct?

]]>http://www.compliancebeat.com/use-interactive-design-code-conduct-three-questions-ricardo-pellafone/feed/0When determining whether to use an interactive design, be sure to spend some time thinking about these three questions: How do your stakeholders interact with your current code of conduct? What is your organization's communication style?When determining whether to use an interactive design, be sure to spend some time thinking about these three questions: How do your stakeholders interact with your current code of conduct? What is your organization's communication style? How do you maintain your code of conduct?Eric Morehead37:14Do we need to train our Board of Directors on compliance and ethics? & Three Questions with JoAnn Mahoneyhttp://www.compliancebeat.com/need-train-board-directors-compliance-ethics-three-questions-joann-mahoney/
http://www.compliancebeat.com/need-train-board-directors-compliance-ethics-three-questions-joann-mahoney/#respondWed, 28 Dec 2016 17:03:54 +0000http://www.compliancebeat.com/?p=1628When training your Board of Directors, you should address the three pillars in board training: risk specific topic, regular review of the Board’s responsibility to oversee the compliance and ethics program and a comprehensive review of employees' and other stakeholders’ code of conduct training.

]]>http://www.compliancebeat.com/need-train-board-directors-compliance-ethics-three-questions-joann-mahoney/feed/0When training your Board of Directors, you should address the three pillars in board training: risk specific topic, regular review of the Board’s responsibility to oversee the compliance and ethics program and a comprehensive review of employees' and o...When training your Board of Directors, you should address the three pillars in board training: risk specific topic, regular review of the Board’s responsibility to oversee the compliance and ethics program and a comprehensive review of employees' and other stakeholders’ code of conduct training.Eric Morehead33:00Compliance Failures & Crisis Management: What can we learn from Baylor University & Penn State?http://www.compliancebeat.com/compliance-failures-crisis-management-can-learn-baylor-university-penn-state/
http://www.compliancebeat.com/compliance-failures-crisis-management-can-learn-baylor-university-penn-state/#respondSat, 24 Dec 2016 14:38:40 +0000http://www.compliancebeat.com/?p=1621Sexual assault allegations rocked two prestigious university football programs, Penn State and Baylor University. Both universities took two different paths to addressing the underlying compliance, governance and risk problems that led to the scandals. Penn State embraced a transparent approach to addressing the problems. In contrast, Baylor's Board of Regents have blocked stakeholders' efforts to understand the root causes of their compliance failures.

]]>http://www.compliancebeat.com/compliance-failures-crisis-management-can-learn-baylor-university-penn-state/feed/0Sexual assault allegations rocked two prestigious university football programs, Penn State and Baylor University. Both universities took two different paths to addressing the underlying compliance, governance and risk problems that led to the scandals...Sexual assault allegations rocked two prestigious university football programs, Penn State and Baylor University. Both universities took two different paths to addressing the underlying compliance, governance and risk problems that led to the scandals. Penn State embraced a transparent approach to addressing the problems. In contrast, Baylor's Board of Regents have blocked stakeholders' efforts to understand the root causes of their compliance failures.Eric Morehead16:53Does the Yates Memo increase my liability as a compliance officer? & Three Questions with Ted Bankshttp://www.compliancebeat.com/yates-memo-increase-liability-compliance-officer-three-questions-ted-banks/
http://www.compliancebeat.com/yates-memo-increase-liability-compliance-officer-three-questions-ted-banks/#respondFri, 16 Dec 2016 01:10:45 +0000http://www.compliancebeat.com/?p=1616The Yates Memo, written by Deputy Attorney General Sally Yates and released on September 9, 2015, addresses individual liability for corporate wrongdoing. In the memo, the DAG Yates lays out new guidance to Department of Justice attorneys who are prosecuting individuals involved in corporate wrongdoing. When you review the data over the years preceding the…

]]>http://www.compliancebeat.com/yates-memo-increase-liability-compliance-officer-three-questions-ted-banks/feed/0The Yates Memo, written by Deputy Attorney General Sally Yates and released on September 9, 2015, addresses individual liability for corporate wrongdoing. In the memo, the DAG Yates lays out new guidance to Department of Justice attorneys who are prose...As a compliance officer or a compliance professional, the Yates Memorandum puts us all on notice that our responsibilities are no different than our expectations for other managers, supervisors and leaders within an organization. Our condoning of, participation in, or turning a blind eye to misconduct or violations of the law can result in us individually having some criminal liability for those actions. We’re now on notice.Eric Morehead30:32“What are the dos and don’ts of written compliance policies?” & Three Questions with Wesley Bizzellhttp://www.compliancebeat.com/dos-donts-written-compliance-policies-three-questions-wesley-bizzell/
http://www.compliancebeat.com/dos-donts-written-compliance-policies-three-questions-wesley-bizzell/#respondWed, 07 Dec 2016 02:20:45 +0000http://www.compliancebeat.com/?p=1611There are some key things to keep in mind when you are planning to update your standalone compliance and ethics policies. The types of stakeholders and subject-matter experts who you will have to consult with are wider and broader than the ones you consult with when rewriting your code of conduct. It will take planning to get them aligned with the end goal. Just as you would in a modern code of conduct, you need to pay attention to the language you use in your policies. Try to reduce jargon and have a conversational tone. Consider design and interactive learning aids where possible. Also, develop a template so that you have a consistent approach across your policies.

]]>http://www.compliancebeat.com/dos-donts-written-compliance-policies-three-questions-wesley-bizzell/feed/0There are some key things to keep in mind when you are planning to update your standalone compliance and ethics policies. The types of stakeholders and subject-matter experts who you will have to consult with are wider and broader than the ones you co...There are some key things to keep in mind when you are planning to update your standalone compliance and ethics policies. The types of stakeholders and subject-matter experts who you will have to consult with are wider and broader than the ones you consult with when rewriting your code of conduct. It will take planning to get them aligned with the end goal. Just as you would in a modern code of conduct, you need to pay attention to the language you use in your policies. Try to reduce jargon and have a conversational tone. Consider design and interactive learning aids where possible. Also, develop a template so that you have a consistent approach across your policies.Eric Morehead26:08“What are the key steps for effective assessment interviews?” & Three Questions with Kathleen Grillihttp://www.compliancebeat.com/key-steps-effective-assessment-interviews-three-questions-kathleen-grilli/
http://www.compliancebeat.com/key-steps-effective-assessment-interviews-three-questions-kathleen-grilli/#respondWed, 30 Nov 2016 14:00:33 +0000http://www.compliancebeat.com/?p=1563As your organization approaches a regular assessment of your compliance and ethics program, consider whether you need to include personnel interviews as part of the process. Many organizations rely solely on benchmarking data and surveys to assess their programs. Time constraints can often prevent a deeper dive into program effectiveness. While not every regular assessment…

]]>http://www.compliancebeat.com/key-steps-effective-assessment-interviews-three-questions-kathleen-grilli/feed/0As your organization approaches a regular assessment of your compliance and ethics program, consider whether you need to include personnel interviews as part of the process. Many organizations rely solely on benchmarking data and surveys to assess thei...As your organization approaches a regular assessment of your compliance and ethics program, consider whether you need to include personnel interviews as part of the process. Many organizations rely solely on benchmarking data and surveys to assess their programs. Time constraints can often prevent a deeper dive into program effectiveness. While not every regular assessment…Eric Morehead24:32“What can we learn about corporate culture from Wells Fargo?” & Creating an Ethical Culture: A Conversation with Robert G. Jones of Old National Bankhttp://www.compliancebeat.com/lessons-can-learn-corporate-culture-wells-fargo-conversation-robert-g-jones-creating-ethical-culture/
http://www.compliancebeat.com/lessons-can-learn-corporate-culture-wells-fargo-conversation-robert-g-jones-creating-ethical-culture/#respondTue, 22 Nov 2016 20:00:02 +0000http://www.compliancebeat.com/?p=1508Where did Wells Fargo go wrong? “Tone from the top” is an often used phrase in the compliance and ethics space. But as the Wells Fargo allegations show us, tone from the top isn’t always enough to ensure that employees on the ground act ethically. In this special edition episode, Eric discusses who defines corporate culture and explains the importance of tone from the middle and how to create it. Eric and the CEO and Chairman of Old National Bancorp discuss how ONB creates and maintains its award-winning corporate culture.

]]>http://www.compliancebeat.com/lessons-can-learn-corporate-culture-wells-fargo-conversation-robert-g-jones-creating-ethical-culture/feed/0Where did Wells Fargo go wrong? “Tone from the top” is an often used phrase in the compliance and ethics space. But as the Wells Fargo allegations show us, tone from the top isn’t always enough to ensure that employees on the ground act ethically.Where did Wells Fargo go wrong? “Tone from the top” is an often used phrase in the compliance and ethics space. But as the Wells Fargo allegations show us, tone from the top isn’t always enough to ensure that employees on the ground act ethically. In this special edition episode, Eric discusses who defines corporate culture and explains the importance of tone from the middle and how to create it. Eric and the CEO and Chairman of Old National Bancorp discuss how ONB creates and maintains its award-winning corporate culture.Eric Morehead21:09“Should we translate our Code of Conduct?” & Three Questions with Ronnie Feldmanhttp://www.compliancebeat.com/translate-code-conduct-three-questions-ronnie-feldman/
http://www.compliancebeat.com/translate-code-conduct-three-questions-ronnie-feldman/#respondWed, 16 Nov 2016 18:48:37 +0000http://www.compliancebeat.com/?p=1499When it comes to translations, there's more to consider than meets the eye. It's important to think about translating your Code of Conduct, even if you are a purely domestic organization. The key is to look closely at your employee population and your stakeholder population to determine what languages are necessary. Lastly don't forget to take a close look at your English version. If your English is too complicated, then your translations will be too complicated.

]]>http://www.compliancebeat.com/translate-code-conduct-three-questions-ronnie-feldman/feed/0When it comes to translations, there's more to consider than meets the eye. It's important to think about translating your Code of Conduct, even if you are a purely domestic organization. The key is to look closely at your employee population and your...When it comes to translations, there's more to consider than meets the eye. It's important to think about translating your Code of Conduct, even if you are a purely domestic organization. The key is to look closely at your employee population and your stakeholder population to determine what languages are necessary. Lastly don't forget to take a close look at your English version. If your English is too complicated, then your translations will be too complicated.Eric Morehead21:33Do the Sentencing Guidelines require an independent chief compliance officer? & Three Questions with Jennifer Badgleyhttp://www.compliancebeat.com/sentencing-guidelines-require-independent-chief-compliance-officer-three-questions-jennifer-badgley/
http://www.compliancebeat.com/sentencing-guidelines-require-independent-chief-compliance-officer-three-questions-jennifer-badgley/#respondWed, 09 Nov 2016 20:09:08 +0000http://www.compliancebeat.com/?p=1487The US Sentencing Guidelines require that individuals within an organization be delegated with day-to-day operational responsibility for the compliance program. When defining the role of this individual, the Guidelines say that the person with day-to-day operational authority shall report to high level personnel, and when appropriate, the governing authority of the organization on the effectiveness of the…

]]>http://www.compliancebeat.com/sentencing-guidelines-require-independent-chief-compliance-officer-three-questions-jennifer-badgley/feed/0The US Sentencing Guidelines require that individuals within an organization be delegated with day-to-day operational responsibility for the compliance program. When defining the role of this individual, the Guidelines say that the person with day-to-d...The US Sentencing Guidelines require that individuals within an organization be delegated with day-to-day operational responsibility for the compliance program. When defining the role of this individual, the Guidelines say that the person with day-to-day operational authority shall report to high level personnel, and when appropriate, the governing authority of the organization on the effectiveness of the…Eric Morehead22:40How can the Sentencing Commission data help you make the case for the importance of a compliance and ethics program? & Three Questions with Amy Lillyhttp://www.compliancebeat.com/can-sentencing-commission-data-help-make-case-importance-compliance-ethics-program-three-questions-amy-lilly/
http://www.compliancebeat.com/can-sentencing-commission-data-help-make-case-importance-compliance-ethics-program-three-questions-amy-lilly/#respondThu, 03 Nov 2016 17:38:16 +0000http://www.compliancebeat.com/?p=1474The U.S. Sentencing Commission's data can tell us some very interesting and helpful things about the size of organizations that get in trouble, the types of offenses or actually the multiplicity of offenses that organizations find themselves charged with probably most importantly can talk very specifically about the collateral damage if you will that comes with a federal prosecution in the form of individuals that get prosecuted. These are all helpful pieces of information and you're making the case internally for the necessity of compliance.

]]>http://www.compliancebeat.com/can-sentencing-commission-data-help-make-case-importance-compliance-ethics-program-three-questions-amy-lilly/feed/0The U.S. Sentencing Commission's data can tell us some very interesting and helpful things about the size of organizations that get in trouble, the types of offenses or actually the multiplicity of offenses that organizations find themselves charged wi...The U.S. Sentencing Commission's data can tell us some very interesting and helpful things about the size of organizations that get in trouble, the types of offenses or actually the multiplicity of offenses that organizations find themselves charged with probably most importantly can talk very specifically about the collateral damage if you will that comes with a federal prosecution in the form of individuals that get prosecuted. These are all helpful pieces of information and you're making the case internally for the necessity of compliance.Eric Morehead22:08What do the Sentencing Guidelines say about training? & Three Questions with David Searlehttp://www.compliancebeat.com/sentencing-guidelines-say-training-three-questions-david-searle/
http://www.compliancebeat.com/sentencing-guidelines-say-training-three-questions-david-searle/#respondFri, 28 Oct 2016 16:57:05 +0000http://www.compliancebeat.com/?p=1461Keep your training effective, periodic and practical. Periodic doesn't mean once and it’s done, it means periodic. Practical means testing to ensure that the program is working. And finally, use consistent and interesting training to ensure effectiveness.

]]>http://www.compliancebeat.com/sentencing-guidelines-say-training-three-questions-david-searle/feed/0Keep your training effective, periodic and practical. Periodic doesn't mean once and it’s done, it means periodic. Practical means testing to ensure that the program is working. And finally, use consistent and interesting training to ensure effectiveness.Keep your training effective, periodic and practical. Periodic doesn't mean once and it’s done, it means periodic. Practical means testing to ensure that the program is working. And finally, use consistent and interesting training to ensure effectiveness.Eric Morehead22:37“Do we need to invest in an anti-corruption program?” & Three Questions with Douglas Veiviahttp://www.compliancebeat.com/need-invest-anti-corruption-program-three-questions-douglas-veivia/
http://www.compliancebeat.com/need-invest-anti-corruption-program-three-questions-douglas-veivia/#respondMon, 24 Oct 2016 23:49:27 +0000http://www.compliancebeat.com/?p=1427While anti-corruption is a very serious risk it is one with very low likelihood for many organizations. Every organization needs to understand their own particular risks. By doing that you will know if you need to have an anti-corruption program.

]]>http://www.compliancebeat.com/need-invest-anti-corruption-program-three-questions-douglas-veivia/feed/0While anti-corruption is a very serious risk it is one with very low likelihood for many organizations. Every organization needs to understand their own particular risks. By doing that you will know if you need to have an anti-corruption program.While anti-corruption is a very serious risk it is one with very low likelihood for many organizations. Every organization needs to understand their own particular risks. By doing that you will know if you need to have an anti-corruption program.Eric Morehead13:55“Should you market the ethics & compliance culture of your organization?” & Three Questions with Erica Salmon Byrnehttp://www.compliancebeat.com/market-ethics-compliance-culture-organization-three-questions-erica-salmon-byrne/
http://www.compliancebeat.com/market-ethics-compliance-culture-organization-three-questions-erica-salmon-byrne/#respondFri, 21 Oct 2016 15:13:47 +0000http://www.compliancebeat.com/?p=1410If you're going to market your program's success either internally or externally be prepared for some scrutiny, be prepared to support that the organization meets “best practices” and most importantly be prepared to continue on the long hard slog to keep the program up to snuff.

]]>http://www.compliancebeat.com/market-ethics-compliance-culture-organization-three-questions-erica-salmon-byrne/feed/0If you're going to market your program's success either internally or externally be prepared for some scrutiny, be prepared to support that the organization meets “best practices” and most importantly be prepared to continue on the long hard slog to ke...If you're going to market your program's success either internally or externally be prepared for some scrutiny, be prepared to support that the organization meets “best practices” and most importantly be prepared to continue on the long hard slog to keep the program up to snuff.Eric Morehead16:22“Why is the United States Sentencing Commission involved in compliance and ethics?” & Three Questions with Tom Foxhttp://www.compliancebeat.com/united-states-sentencing-commission-involved-compliance-ethics-three-questions-tom-fox/
http://www.compliancebeat.com/united-states-sentencing-commission-involved-compliance-ethics-three-questions-tom-fox/#respondMon, 17 Oct 2016 17:04:14 +0000http://www.compliancebeat.com/?p=1402 This is part of a continuing series called Sentencing Commission Confidential. Let’s take a look at the history and operation of the sentencing guidelines and in particular chapter 8 of the sentencing guidelines that have to do with organizations. Let’s go back in time to 1984, this was before the United States Sentencing Commission.…

]]>http://www.compliancebeat.com/united-states-sentencing-commission-involved-compliance-ethics-three-questions-tom-fox/feed/0 This is part of a continuing series called Sentencing Commission Confidential. Let’s take a look at the history and operation of the sentencing guidelines and in particular chapter 8 of the sentencing guidelines that have to do with organizations. This is part of a continuing series called Sentencing Commission Confidential. Let’s take a look at the history and operation of the sentencing guidelines and in particular chapter 8 of the sentencing guidelines that have to do with organizations. Let’s go back in time to 1984, this was before the United States Sentencing Commission.…Eric Morehead12:21“What is the best defense against a Whistleblower?” & Three Questions with Dick Dubehttp://www.compliancebeat.com/best-defense-whistleblower-three-questions-dick-dube/
http://www.compliancebeat.com/best-defense-whistleblower-three-questions-dick-dube/#commentsFri, 14 Oct 2016 17:34:49 +0000http://www.compliancebeat.com/?p=1385If you want to avoid having a whistleblower you need to focus on your culture. Invest in middle management and understand the perception of retaliation in your organization these three things overlap and there are vitally important to keeping people reporting inside your organization.

]]>http://www.compliancebeat.com/best-defense-whistleblower-three-questions-dick-dube/feed/1If you want to avoid having a whistleblower you need to focus on your culture. Invest in middle management and understand the perception of retaliation in your organization these three things overlap and there are vitally important to keeping people re...If you want to avoid having a whistleblower you need to focus on your culture. Invest in middle management and understand the perception of retaliation in your organization these three things overlap and there are vitally important to keeping people reporting inside your organization.Eric Morehead15:12“What does a foundation mean?” & Three Questions with Nicole Tarasoffhttp://www.compliancebeat.com/foundation-mean-3-questions-nicole-tarasoff/
http://www.compliancebeat.com/foundation-mean-3-questions-nicole-tarasoff/#respondWed, 12 Oct 2016 15:16:22 +0000http://www.compliancebeat.com/?p=1372The Code of Conduct is the Foundation Why does the Department of Justice and the SEC call the Code of Conduct the foundation of an effective compliance and ethics program? This question is something that has come up often over the last few years and this terminology— the foundation has become a buzzword. Let’s take a…

]]>http://www.compliancebeat.com/foundation-mean-3-questions-nicole-tarasoff/feed/0The Foundation of a Compliance ProgramThe Code of Conduct is the foundation of your program. It's got to be solid and well maintained must be purpose built for your unique organization. It must support your program and states the values of your organization and lastly it must be maintained.Eric Morehead16:31SCCE Conference Highlights-Special Editionhttp://www.compliancebeat.com/scce-conference-highlights-special-edition/
http://www.compliancebeat.com/scce-conference-highlights-special-edition/#respondThu, 06 Oct 2016 17:30:59 +0000http://www.compliancebeat.com/?p=1360The SCCE Compliance and Ethics Institute Conference in Chicago on September 24-27, 2016 is the stage for this podcast. Eric Morehead, host of Compliance Beat was in attendance, along with 1700 compliance professionals and shares conference highlights and emerging trends in this Special Edition.

]]>http://www.compliancebeat.com/scce-conference-highlights-special-edition/feed/0SCCE Conference HighlightsThe SCCE Compliance and Ethics Institute Conference in Chicago on September 24-27, 2016 is the stage for this podcast. Eric Morehead, host of Compliance Beat was in attendance, along with 1700 compliance professionals and shares conference highlights and emerging trends in this Special Edition.Eric Morehead12:21“Do I always have to be the one that says No?” & Three Questions with Richard Bistronghttp://www.compliancebeat.com/always-one-says-no-three-questions-richard-bistrong/
http://www.compliancebeat.com/always-one-says-no-three-questions-richard-bistrong/#respondMon, 03 Oct 2016 19:23:54 +0000http://www.compliancebeat.com/?p=1354Do you have to be the person that says “no”? Compliance officers often struggle with the push and pull of keeping the lines of communication open and also having to deliver difficult answers to their stakeholders. What are some strategies for avoiding being known as the person who always says “no”? We discuss some ideas…

]]>http://www.compliancebeat.com/always-one-says-no-three-questions-richard-bistrong/feed/0Do you have to be the person that says “no”? Compliance officers often struggle with the push and pull of keeping the lines of communication open and also having to deliver difficult answers to their stakeholders.Do you have to be the person that says “no”? Compliance officers often struggle with the push and pull of keeping the lines of communication open and also having to deliver difficult answers to their stakeholders. What are some strategies for avoiding being known as the person who always says “no”? We discuss some ideas…Eric Morehead20:33“Does the DOJ require an independent compliance officer?” & Three Questions with Bill Brownhttp://www.compliancebeat.com/need-independent-compliance-committee-threequestions-three-questions-bill-brown/
http://www.compliancebeat.com/need-independent-compliance-committee-threequestions-three-questions-bill-brown/#respondFri, 30 Sep 2016 17:13:47 +0000http://www.compliancebeat.com/?p=1348The USDOJ has required an independent compliance function in some recent corporate settlements, but is this the official position of the Department? We discuss the the intersection of these recent developments, the US Federal Sentencing Guidelines and how this might relate to whether your compliance officer has the necessary independence to craft and maintain a…

]]>http://www.compliancebeat.com/need-independent-compliance-committee-threequestions-three-questions-bill-brown/feed/0The USDOJ has required an independent compliance function in some recent corporate settlements, but is this the official position of the Department? We discuss the the intersection of these recent developments,The USDOJ has required an independent compliance function in some recent corporate settlements, but is this the official position of the Department? We discuss the the intersection of these recent developments, the US Federal Sentencing Guidelines and how this might relate to whether your compliance officer has the necessary independence to craft and maintain a…Eric Morehead13:27